Fulton County Superior Court

***EFILED***FD
Date: 1/8/2024 4:42 PM
Che Alexander, Clerk

IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

STATE OF GEORGIA, )
)
v. ) INDICTMENT NO.
) 23SC188947
MICHAEL A. ROMAN, )
)
Defendant. )
____________________________________)

DEFENDANT MICHAEL ROMAN’S MOTION TO

DISMISS GRAND JURY INDICTMENT AS FATALLY
DEFECTIVE AND MOTION TO DISQUALIFY THE
DISTRICT ATTORNEY, HER OFFICE AND THE SPECIAL
PROSECUTOR FROM FURTHER PROSECUTING THIS MATTER

COMES NOW, Defendant Michael Roman (“Mr. Roman”), by and through his

undersigned counsel, and, pursuant to O.C.G.A. § 15-18-20, the Fifth and Fourteenth

Amendments to the United States Constitution, Article I, Section I, Paragraph I and Article

VI, Section VIII, Paragraph I of the Georgia Constitution, the inherent supervisory powers

of this Court, the Georgia Rules of Professional Responsibility, and other law set forth

herein, moves this Honorable Court for an order striking the special purpose grand jury

report and dismissing the criminal indictment in its entirety against Mr. Roman on the

grounds that the entire prosecution is invalid and unconstitutional because the Fulton

County district attorney never had legal authority to appoint the special prosecutor, who

assisted in obtaining both grand jury indictments. As a result, both indictments contain

structural errors and irreparable defects and should be dismissed in their entirety as to Mr.

Roman.1 Mr. Roman also moves the Court for an order disqualifying the district attorney,

1
Notably, the special purpose grand jury did not recommend an indictment or any charges
against Mr. Roman. The district attorney and special prosecutor made that charging
decision on their own.
her office, and the special prosecutor from further prosecuting the instant matter on the

grounds that the district attorney and the special prosecutor have been engaged in an

improper, clandestine personal relationship during the pendency of this case, which has

resulted in the special prosecutor, and, in turn, the district attorney, profiting significantly

from this prosecution at the expense of the taxpayers.

Accordingly, the district attorney and the special prosecutor have violated laws

regulating the use of public monies, suffer from irreparable conflicts of interest, and have

violated their oaths of office under the Georgia Rules of Professional Conduct and should

be disqualified from prosecuting this matter. In further support of the instant motions, Mr.

Roman respectfully shows the Court as follows:

INTRODUCTION

The instant Motion is not filed lightly. Nor is it being filed without considerable

forethought, research or investigation. Nonetheless, this Motion must be heard, as the

issues raised herein strike at the heart of fairness in our justice system and, if left

unaddressed and unchecked, threaten to taint the entire prosecution, invite error, and

completely undermine public confidence in the eventual outcome of this proceeding.

There are fewer positions of authority in Georgia’s justice system more powerful

than an elected district attorney. The district attorney has incredible control and influence

over the entire criminal judicial process, including the power to decide who and when to

charge and how to charge them, which cases will get tried and which cases will be resolved,

and, importantly the power to allocate public monies provided for the operation of the

district attorney’s office. Historically, there have been few checks on this power in

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Georgia, and district attorneys have largely been able to act with broad discretion in

deciding how to utilize public monies and making prosecutorial decisions.

This case presents a unique opportunity for this Court to review this authority and

determine if the district attorney here overstepped her legal discretion and authority and

whether she and the special prosecutor violated the law and their obligations under the

Georgia Rules of Professional Conduct when they engaged in a personal, romantic

relationship that has ultimately yielded substantial income to the special prosecutor. The

important issues raised in the instant Motion suggest that the elected district attorney for

the largest district attorney’s office in the State of Georgia has used the instant prosecution

to pay her partner a large sum of money that was originally allotted to clear the backlog of

cases in Fulton County following the Covid pandemic.

Normally, the district attorney’s use of funds allotted pursuant to a county’s prior

approval would not be newsworthy or legally actionable. But this case is different. The

district attorney sought additional funds from Fulton County to clear the Covid backlog,

including making a detailed presentation to the Board of Commissioners in 2021, and she

ultimately received that funding from Fulton County. But she has not used those funds for

that purpose. She apparently has used them to prosecute this case. Even assuming that

were proper and could be forgiven, even within the contours of this prosecution, there is a

separate and very important concern about her use of the money. As the layers unfold, it

becomes clear that the district attorney and the special prosecutor have been profiting

personally from this prosecution at Fulton County’s expense. Instead of handling this case

within her office, as she could have done given the influx of Covid money, she chose to

hire a private special prosecutor to preside over the case. Once again, on its face, this is

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not earth-shattering, and generally well within her discretion—but there are several

important facts that distinguish this case from the typical one, and which render the

indictment invalid as a matter of law.

Under Georgia law, the district attorney was required to obtain Fulton County’s

approval prior to appointing the special prosecutor to work on the case. The reason for this

requirement is simple; it ensures that the district attorney cannot act unilaterally with regard

to public monies and is subject to the control and supervision of the governing body, i.e.,

Fulton County so that public has confidence in how the money is used. Undersigned

counsel has found no evidence that the district attorney sought or received such approval

to appoint the special prosecutor from Fulton County. This is not a mere technicality. It

is a requirement the Georgia Supreme Court has held must be followed when a special

prosecutor is appointed, and, therefore, a prerequisite for any special prosecutor’s work on

a case including the instant case.

Since the district attorney was fully capable of asking for authority for additional

funding following the pandemic, then it is clear she knows how to do that. So that begs

the question of why she did not do so with regard to the approval for the special prosecutor

in this case. One could assume it was an oversight, but digging deeper the potential reason

becomes obvious. As has been pointed out in prior filings, the special prosecutor’s oath of

office was never filed. While this may have been an oversight, it may have been

purposeful—a specific attempt to shield from public knowledge the fact that the special

prosecutor had, in fact, been appointed without legal authority. Perhaps more important

and enlightening, however, is the identity and qualifications of the specific person the

district attorney chose to put in charge of this prosecution.

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 The district attorney chose to appoint her romantic partner, who at all times relevant

to this prosecution has been a married man. Admittedly, this is a bold allegation

considering it is directed to one of the most powerful people in the State of Georgia, the

Fulton County District Attorney. Nevertheless, the district attorney’s fame and power do

not change the fact that she decided to appoint as the special prosecutor a person with

whom she had a personal relationship and who is now leading the day-to-day prosecution

of this case. Even assuming this type of nepotism might be forgiven in the abstract, a

review of the amount of money that the special prosecutor has been paid by the district

attorney and the personal activities of the district attorney and the special prosecutor during

the pendency of this prosecution shed light on just how self-serving this arrangement has

been.

The Court may well be wondering, and for good reason, “How do you know this?”

and “Why does it matter?”

How Do We Know This?

 Open records requests to Fulton County reveal that the district attorney did
not obtain county approval to appoint the special prosecutor. Why would
the district attorney not obtain this approval prior to appointing the special
prosecutor?

 The special prosecutor has admitted his oath was not filed prior to his work
on this case. Why would the special prosecutor not just file the oath, a
simple administrative task for a lawyer?

 The special prosecutor is seeking a divorce in Cobb County and sought

successfully to seal those records, hiding them from public view. Why
would a private citizen such as the special prosecutor shield filings related
to his income and spending from public view?

 While the filings in the divorce case are sealed by Court order (the legality
of which is open to question), information obtained outside of court filings
indicates that the district attorney and special prosecutor have traveled
personally together to such places as Napa Valley, Florida and the

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 Caribbean and the special prosecutor has purchased tickets for both of them
to travel on both the Norweigan and Royal Carribean cruise lines. Traveling
together to such places as Washington, D.C. or New York City might make
sense for work purposes in light of other pending litigation, but what work
purpose could only be served by travel to this traditional vacation
destinations?

 The district attorney and the special prosecutor have been seen in private
together in and about the Atlanta area and believed to have co-habited in
some form or fashion at a location owned by neither of them.

 Sources close to both the special prosecutor and the district attorney have
confirmed they had an ongoing, personal relationship during the pendency
of the special prosecutor’s divorce proceedings.

 According to these sources, the personal relationship between the district

attorney and the special prosecutor began before this prosecution was
initiated and before the district attorney appointed the special prosecutor.

 Undersigned counsel knows the special prosecutor and has researched his
litigation experience. That research reveals that the special prosecutor has
never tried a felony RICO case. The State of Georgia and the City of Atlanta
has several lawyers who specialize in the prosecuting and defending RICO
cases. Despite having access to these resources, why would the district
attorney, instead, appoint someone who has never tried a felony RICO case,
particularly in a case with such national significance as this one?

 The special prosecutor, based on his lack of experience in this type of

felony, would not be qualified under Fulton County’s standards to be
appointed to represent any defendant in this case given the complexity of
the charges. If the special prosecutor is not qualified to defend this case
under Fulton County’s standards, then how is he qualified to prosecute the
case? Is that why the district attorney did not seek approval for his
appointment? If so, why did she seek to appoint an unqualified lawyer
without approval to preside over this prosecution?

 Since being appointed as special prosecutor, the special prosecutor has been
paid an estimated almost $1,000,000.00 in legal fees. Of course, additional
fees would be expected when private counsel is hired, but that would
assume they are not in a relationship with the district attorney and they were
qualified to do the work they were hired to do.

 The special prosecutor’s fees have been lucrative in comparison by any

reasonable measure. The district attorney’s yearly salary, including state
and county supplements, is $ 198,266.66 and the total annual budget for the
Fulton County District Attorney’s Office for fiscal year 2022 was $

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 31,541,968.00. The district attorney lobbied for additional money from
Fulton County to hire lawyers and staff to clear the backlog after Covid.
Why didn’t she use that money to hire qualified in-house staff to try this
case? Why did she, instead, use that money to retain the special prosecutor?

Why Is This Important?

 The district attorney’s failure to obtain the required approval to appoint the
special prosecutor prior to him obtaining indictments against Mr. Roman
renders the special prosecutor’s service in that role a nullity and without
effect under Georgia law, so the indictments he assisted in securing suffer
from a structural and irreparable defect and must be dismissed.

 In light of the district attorney’s personal relationship to the special

prosecutor prior to his appointment as the special prosecutor, his
appointment created an impermissible and irreparable conflict of interest
under Georgia’s Rules of Professional Conduct, which requires the
disqualification of both lawyers and their respective offices and firms.

 The district attorney’s apparent intentional failure to disclose her conflict of

interest to Fulton County and the Court, combined with her decision to
employ the special prosecutor based on her own personal interests may well
be an act to defraud the public of honest services since the district attorney
“personally benefitted from an undisclosed conflict of interest” which is a
crime under 18 U.S.C. § 1346 as well as a predicate act which could result
in a RICO charge against both the district attorney and the special
prosecutor.

 Putting aside both the legal and ethical implications of their conduct, their
conduct also undermines the sanctity of the criminal justice system, erodes
public trust in our judicial system, and would place them above the law. To
allow this conduct to go unchecked by a powerful, public, elected official
threatens to undermine the very principles of democracy that the district
attorney herself claims to defend in this prosecution. It seems hard to
believe that such a powerful person could escape scrutiny and
accountability for such egregious conduct simply because she believes she
maintains a moral high ground and holds one of the powerful positions in
the State of Georgia. This is particularly true since she has used that
platform and the megaphone it provides to tour the country giving
interviews in her pursuit of a conviction.

It is for these reasons and the other important reasons set forth below that the instant

motion is being filed. The actions of the district attorney and the special prosecutor are

indefensible under the law and our Rules of Professional Conduct and have ultimately

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created a fatal and irreparable defect in the indictment against Mr. Roman and a conflict of

interest that has tainted the entire prosecution. To allow either of them to stand above the

law would be to invite and encourage the same behavior in the future, so Mr. Roman

respectfully requests that the Court grant the instant and dismiss the indictment in its

entirety as to Mr. Roman. Mr. Roman also respectfully requests that the Court disqualify

Willis, Wade and their respective offices and firms from any further involvement in the

prosecution of this matter.

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 FACTUAL BACKGROUND

I. WILLIS AND WADE HAVE ENGAGED IN A PERSONAL RELATIONSHIP BOTH

BEFORE AND AFTER WILLIS APPOINTED WADE AS THE SPECIAL PROSECUTOR
IN THE INSTANT CASE.

Upon information and belief, and based on discussions with individuals with

knowledge, Willis and Wade were romantically involved prior to Willis awarding a

contract for legal services with Wade. It is not entirely clear when the relationship began,

but it began while Wade was married. On November 2, 2021, a day after his first contract

with Willis commenced, Wade filed for divorce in Cobb County Superior Court. (See

Cobb County Civil Case Docket Number 21108166). Wade then had the divorce

proceedings sealed by consent order on February 10, 2022.2

While the filings in the divorce case are sealed by Court order, undersigned counsel

has learned that Willis and Wade have traveled personally together to such places as Napa

Valley, California, Florida and the Caribbean and Wade has purchased tickets for both of

them to travel on both the Norweigan and Royal Carribean cruise lines. Wade has also

purchased hotel rooms for personal trips with funds from the same account used to receive

payments under his contract with Willis.

2
This order appears to have been signed as a “consent” order sealing the record and the
required hearing was not held prior to this order being entered. Therefore, the order is void
and, if requested by any third party, should be unsealed by the Court. However, without
knowing the record had been sealed and prior to the Court Clerk actually sealing the record,
undersigned counsel was able to view this record and obtain copies of certain documents
that had been filed upon review of the file at the Clerk’s office. Now that the record is
sealed, undersigned counsel is seeking to have these records unsealed and will not discuss
the contents of the sealed records in this public pleading until either the records are
unsealed by the Court in Cobb County or this Court conducts a proceeding under seal where
counsel can share said pleadings and information under seal.

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 In addition, the district attorney and the special prosecutor have been seen in private

together (in a personal relationship capacity) in and about the Atlanta area and believed to

have co-habited in some form or fashion at a location that neither of them owned. Sources

close to both the special prosecutor and the district attorney have confirmed Willis and

Wade had an ongoing, personal and romantic relationship during the pendency of Wade’s

divorce proceedings.

II. WILLIS CONTRACTED WITH WADE WITHOUT THE REQUIRED APPROVAL OF

FULTON COUNTY AND FAILED TO DISCLOSE HER PERSONAL RELATIONSHIP
WITH WADE BEFORE CONTRACTING WITH HIM.

There is no evidence Willis was authorized by Fulton County to use county funds

to retain Wade to assist in prosecuting this case.3 In July 2021, Willis presented to the

Fulton County Board of Commissioners (“BOC”) requesting funding for the criminal case

back log caused by the COVID-19 pandemic. Willis told the BOC that she needed these

funds for “historical backlog”, “COVID backlog” and “crime on the rise”. (Exhibit A-B).

The historical mismanagement backlog was for cases from 2016 to 2019. (Exhibit A-B.

The COVID backlog was for unindicted cases from March 2020 to June 2021. (Exhibit A-

B). The “crime on the rise” focused on the number of rapes and murders in Fulton County

from July 2020 to July 2021. (Exhibit A-B). Willis told the BOC that it was a crisis and

that without additional funding “approximately 1,433 violent defendants” would

potentially be released into the community. (Exhibit A-B).

On September 15, 2021, the BOC approved Willis’ request for additional funding.

(Exhibit C). The BOC approval is noted in a “resolution”, item #21-0691, dated September

3
Fulton County responded to open records requests for any such written authorization by
stating no records exist.

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15, 2021, which authorized additional county funding for Willis’ personnel needs to

respond to the “historic backlog of cases” and the “current high crime rate” in Fulton

County. (Exhibit C). Willis was awarded these additional county funds to “investigate

and prosecute these backlogged criminal cases and respond adequately to the increased

crime rate and increased number of cases received”. Id. Undersigned counsel has

confirmed, through open records requests and direct inquiry with representatives for Fulton

County, that Willis did not seek or receive authorization to contract or pay Wade as outside

counsel to serve in the capacity of a special prosecutor. Co-defendant’s counsel spoke

directly with a Fulton County Commissioner who verified that Willis never got approval

for Wade to be appointed or paid.

In addition, undersigned counsel has been unable to find any evidence that Willis

has ever disclosed the personal nature of her relationship to Wade to the BOC prior to

contracting with Wade as a special prosecutor.

III. WADE DID NOT FILE ANY OATH OF OFFICE AS REQUIRED BY LAW.

Wade swore both an Oath of Special Assistant District Attorney, and a Loyalty

Oath. The Oath of Special Assistant District Attorney was sworn on November 1, 2021,

before the Honorable Judge Belinda Edwards. The Loyalty Oath was sworn on November

25, 2021, and was notarized. The Loyalty Oath was not filed, as required by statute, until

September 27, 2023, which was after Wade had appeared and participated in both the SPGJ

and the GJ in this case.

Thus, at the time Wade appeared before and assisted the SPGJ, he had not filed an

oath of office as a special prosecutor in any Georgia court and was not under a valid

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employment contract with Willis.4 Despite this, Wade signed numerous subpoenas for the

SPGJ as a “special prosecutor” with the power of the State to command appearance. Wade

obtained court orders to compel the attendance of out-of-state witnesses and to compel

witnesses who were asserting privilege or immunity from testifying. Wade negotiated legal

immunity deals on behalf of the State for certain witnesses appearing before the SPGJ.

Wade then presented this indictment to a criminal grand jury on behalf of the State of

Georgia. Wade has represented to the public, defense counsel, and this Court that he is a

duly authorized special prosecutor and has filed pleadings into the court record.

IV. WADE’S LACK OF RELEVANT EXPERIENCE, HIS CONTRACTS WITH WILLIS AND
WADE’S SUBSTANTIAL INCOME IN CONNECTION WITH THE INSTANT CASE.

The Fulton County District Attorney’s Office (“FDCA”) is the largest district

attorney’s office in the State of Georgia. As a result, FCDA has numerous experienced

lawyers fully capable of preparing this case for the grand jury and trial. Willis, however,

contracted with Wade and his law firm to be a special prosecutor to be paid as a private

4
Wade has represented to attorneys in this matter that he is the “only individual in the
DA’s office who had authority to enter into agreements pertaining to the investigation”.
See Motion to Quash Subpoena Issued To Governor Brian P. Kemp and Memorandum in
Support, Filed in Case 2022-EX-00024The communications between counsel for Governor
Kemp and Wade indicate that Wade was serving as lead counsel for the SPGJ.
Additionally, the FCDA’s response filed as “Opposition to Motion To Disqualify
Prosecutor” filed July 19, 2022 in 2022-EX-00024,also indicate that Wade served
alongside Willis as a “special prosecutor” and that he was in charge of the SPGJ
investigation.

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law firm hourly for the work. Based on her longstanding personal knowledge of Wade

and additional research, undersigned counsel is unaware of, and is unable to find any

history of, Wade ever having prosecuted a single felony trial, much less at the rate Willis

is paying him. Based on his current experience, and based on the current appointment

guidelines, Mr. Wade would not be qualified to serve as defense counsel in this RICO case

because he has not tried “at least two criminal trials of similar offenses.” (Exhibit D). In

addition, assuming he could be appointed, he would only be paid a rate of $140.00 per

hour. (Id.).

Wade’s initial contract with Willis commenced on November 1, 2021, and was in

effect until October 31, 2022. The only copy of this “contract” that FCDA has is a copy

labeled an “Addendum” that was not signed until March 1, 2022 and permitted Wade to be

reimbursed for any work-related travel that was “associated with the performance of

duties”. (Exhibit E). On November 2, 2021, one day after the initial contract commenced,

Wade filed his Complaint for Divorce in Cobb County Superior Court, docket number

21108166. Upon information and belief, Willis and Wade had already begun a personal,

romantic relationship with each other. Willis’ initial contract with Wade does not identify

any hourly rate or specific parameters on how much Wade was to be paid under the

contract. During this year-long period, however, Wade was paid a total of $299,700.00

and received $3,526.51 as reimbursement for travel. Wade’s invoices for his services in

connection with the instant case were broken down as follows:

 Invoice #1 was for November 2021 work for $15,000.005

 Invoice #2 was for December 2021 work for $15,000.00

5
On November 5, 2021, Wade’s invoice is for 24 hours of work.

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  Invoice #3 was for January 2022 work for $15,000.00

 Invoice #4 was for February 2022 work for $9,250.00

 Invoice #5 was for March 2022 work for $32,450.00

 Invoice #6 was for April 2022 work for $33,750.00

 Invoice #7 was for “reimbursement” for travel costs to Denver and

Washington DC of $3,526.51.00

 Invoice #8 was for May 2022 work or $33,500.00

 Invoice #9 was for June 2022 work for $34,000.00

 Invoice #10 was for July 2022 work for $34,000.00

 Invoice #11 was for August 2022 work for $35,000.00

 Invoice #12 was for September 2022 work for $35,000.00

 Invoice #13 was for October 2022 work for $7,750.006

The first three invoices were paid for out of the “confiscated funds/ seized property”

fund and the remaining were paid out of the County “general” fund. (Exhibit F).

The second contract between Willis and Wade covered the period November 15,

2022 through May 15, 2023, and provided for payment to Wade at the rate of $250.00 per

hour for up to 600 hours for a cap of $150,000.00 during this contract period. (Exhibit G).

That contract was not signed until June 12, 2023. (Exhibit G).7 Wade was paid at total of

$173,500.00 under the second contract. The invoices were broken down as follows:

 Invoice #14 was for November 2022work for $25,250.00

 Invoice #15 was for December 2022 work for $23,250.00

6
All of these invoices are attached collectively hereto as Exhibit “F”.
7
Based on the foregoing, it appears that Willis and Wade did not have an executed contract
for his firm’s services in connection with this case at any time while Wade was involved
in assisting the SPGJ or presenting the case to the criminal grand jury.

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  Invoice #16 was for January 2023 work for $20,000.00

 Invoice #17 was for February 2023 work for $34,000.00

 Invoice #18 was for March 2023 work for $36,000.00

 Invoice #19 was for April 2023 work for $35,000.00.8

The third contract between Willis and Wade covered the period June 12, 2023,

through December 31, 2023, and provided for payment to Wade at the rate of $250.00 per

hour for up to a total of $210,000.00.9 According to the terms of the third contract, if Wade

needed to work beyond these limits, he could seek written approval from Willis to do so.

(Id.) As of June 2023, Wade has been paid approximately $548,977.00 from FCDA for

his work with the “anti-corruption” unit.10 As of December 2023, Wade has been paid a

8
The foregoing invoices are attached collectively hereto as Exhibit “H”.
9
A copy of the third contract is attached hereto as Exhibit “I”. Notably, there is no contract
for the period May 15, 2023, through June 12, 2023, on file or referenced in any of the
contracts that are on file, but if the prior amounts hold true, Wade’s total compensation
under contracts with Willis likely total close to or more than $1,000,000.00.
10
Wade’s law partner, Chris Campbell, also entered into agreements with Willis to provide
legal services. On March 1, 2021, Campbell entered into an agreement to serve as an
attorney in the anti-corruption unit of the FCDA. Campbell served as an attorney tasked
with reviewing confidential materials provided to law enforcement to determine whether
the FCDA’s Anti-Corruption unit could legally possess said materials. He was also tasked
with, after determining that these materials could be provided to Wade and his team,
providing said confidential materials to the Chief Investigator of the Anti-Corruption unit
of the FCDA.

To date, Campbell has been paid approximately $126,070.00 by FCDA and is still under
contract to receive more. Wade is a “partner” at Wade & Campbell Firm, LLC according
to the company website and the State Bar of Georgia. However, there are no Georgia
corporations registered as such an entity but there are separate entities for Nathan J. Wade,
P.C., and Christopher A. Campbell, P.C. A recent mailer indicated that Wade and
Campbell are operating and advertising as law partners. Additionally, Wade’s address on
file with the Georgia Bar also indicates they are operating as partners as does their law firm
website.

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total of $653, 881 which does not include all of his billing to date and does not include the

amounts paid to his law firm through his partners.

In comparison, Willis receives $129,473.00 as a salary from the State of Georgia,

plus an additional $6,000 accountability supplement, plus an additional $62,793.66

supplement from Fulton County for a total annual salary of $198,266.66. See

https://openpayrolls.com/fani-willis-131675566 (last accessed on January 6, 2024). The

amounts Wade has been paid under the contracts is far greater than the justices on the

Supreme Court of Georgia. The Judicial Council of Georgia recently recommended the

Supreme Court justices receive a pay increase from their current $186,112.00 to

$223,400.00 per year. See https://www.ajc.com/politics/top-georgia-judges-seek-big-pay-

raises-from-lawmakers-in-2024/LZMALVNIXRD2JJYKLXIUBO5JX4/ (last accessed

January 6, 2024). Also, as noted above, some amount of Wade’s income has been used to

travel with Willis to traditional vacation destinations and they may have done so with

certain members of their families.

Wade’s former partner, Terrence Bradley, also entered into agreements with Willis to
provide legal services. Prior to Bradley and Wade dissolving their law firm, Bradley had
been paid a total of $74, 480. After dissolving their association, Bradley no longer received
funds from FCDA.

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 ARGUMENT AND CITATION TO AUTHORITY

I. THE INDICTMENT AGAINST MR. ROMAN IS INVALID AND VOID BECAUSE IT WAS
SOUGHT AND OBTAINED, IN PART, BY WADE, BUT WILLIS NEVER HAD
AUTHORITY FROM THE GOVERNING AUTHORITY, FULTON COUNTY, GEORGIA,
TO APPOINT WADE AS A SPECIAL PROSECUTOR AND WADE NEVER FILED HIS
OATH OF OFFICE PRIOR TO HIS WORK ON THIS CASE.

A. When Willis Failed To Obtain Prior Approval From Fulton County To

Contract With Wade, She Failed To Comply With O.C.G.A. § 15-18-20, So
She Was Without Authority To Appoint Wade.

Under O.C.G.A. § 15-18-14, an elected district attorney appoints assistant district

attorneys who serve only at the district attorney’s pleasure. An elected district attorney also

has the power and authority to appoint “special assistant district attorneys.” See GA. UNIF.

SUPER. CT. R. 42.1. All personnel employed by the district attorney derive their authority

from the district attorney. O.C.G.A. §§ 15-18-19(b), 15-18-20(b). In other words, the entire

proceeding of a Georgia criminal prosecution—from the time the case is laid before the

prosecutor until the rendition of the verdict—is under the direction, supervision, and

control of that officer, subject to such restriction as the law imposes. The Georgia Supreme

Court has long held that “[c]ounsel employed to assist in the prosecution of criminal cases

can perform no duties as such, except those agreeable to and under the direction of the

[district attorney].” Jackson v. State, 120 S.E. 535, 539 (Ga. 1923).

The discretion the district attorney enjoys over employees of her office, however,

does not extend in the same way to non-employees such as special prosectuors. With

respect to special prosecutors, the district attorney’s power and authority to appoint special

prosecutors requires the appointment to be affected pursuant to either O.C.G.A. § 15-18-

20 or, in the case of a potential conflict, O.C.G.A. § 15-18-5. Willis has not recused herself

from this prosecution. Thus, Wade’s appointment would fall under O.C.G.A. § 15-18-20.

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 That statute provides that such an appointment is legal if, “provided for by local

law or . . . authorized by the governing authority of the county.” O.C.G.A. § 15-18-20(a).

Although the statute authorizes the district attorney to employ additional prosecutors who

are compensated from county funds,11 the Georgia Supreme Court has made clear that this

authority is expressly conditioned upon prior approval of the governing authority of the

county. Wilson v. Southerland, 371 S.E.2d 382, 383 (1988). In addition, Section 102-82 of

the Fulton County Laws also requires outside counsel to be selected and approved by the

Board of Commissioners.

Applying the above principles to the case at hand, the indictment must be dismissed

because it was obtained by a special prosecutor who had no legal authority to act since

Willis never had authority from Fulton County to contract with Wade. It appears evident

that Willis did not obtain prior approval to contract with Wade as a special prosecutor.

There is no documentation and no other evidence in Fulton County’s public records that

show the BOD approved Wade.12 Indeed, Fulton County indicated that no such records

exist. Willis also did not obtain the BOD’s approval for her selection of Wade as outside

counsel, so she violated Section 102-82 of the Fulton County Laws.

Since Willis knew how to obtain approval for additional funding and made a full

11
The “[p]ersonnel employed by the district attorney . . . shall be compensated by the
county,” and “the manner and amount of compensation to be paid to be fixed either by
local Act or by the district attorney with the approval of the county. . . .” O.C.G.A. § 15-
18-20(b) (emphasis added).
12
While Fulton County did provide evidence of its authorization to utilize additional funds
to clear the backlog of cases due to the Covid pandemic and other specific types of cases,
there was no authority for Willis to use funds to retain a special prosecutor in connection
with the prosecution of the instant matter. (Exhibit C). As an example, Exhibit J is attached
for illustrative purposes to show what Fulton County documents when an independent
contractor agreement is approved by the County for outside legal services.

- 18 -
presentation to the BOD for that purpose in 2021, then she knew how to obtain permission

for funding from the BOD. Yet, she specifically chose not to obtain the required

authorization from the BOD to retain Wade as a special prosecutor. Why? Placed in the

context of her other actions outlined herein, the answer becomes obvious: She knew the

BOD would ask her about her relationship with Wade and his experience—both questions

she did not want to answer. With her power as the district attorney, perhaps she thought

no one would notice or care and she would ask for forgiveness (not permission) later. In

any event, she acted without approval from the governing authority, so Willis violated and

failed to comply with O.C.G.A. §15-18-20(a) and she had no authority to delegate to any

prosecutorial responsibilities to Wade.13 Wilson v. Southerland, 371 S.E.2d 382, 383

(1988).

Since Willis never had any authority from Fulton County to contract with Wade as

a special prosecutor, Wade, in kind, had no authority to investigate this case or seek an

indictment. Accordingly, the indictment is fatally defective and must be dismissed.

13
Wade’s contract is not provided for by local law. Nor, based upon information and belief
and responses to records requests, has it been approved or authorized by the Fulton County
Board of Commissioners or any other governing authority for the County. Instead, Wade’s
contract appears to be authorized solely by the District Attorney without the County being
involved in such an agreement other than to supply taxpayer funds to pay Wade. And if
the County had been asked to approve such a contract, it would have been unable to since
it is in clear violation of the Counties “Code of Laws” as well as the amounts that are
typically approved for outside counsel.

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 B. Wade Never Filed His Oath Of Office Prior To Beginning Work On This
Case, So He Was Never Duly Authorized Under Georgia Law To Serve In
His Role As Special Prosecutor.14

Despite being paid these large amounts of money and representing himself as a duly

authorized “special assistant district attorney”, Wade was never statutorily authorized

under Georgia law to act in the role of a public officer when he presented the instant case

to the SPGJ and GJ. Willis’ lack of authority to appoint him notwithstanding, Wade also

was not authorized under Georgia law to prosecute this matter because he and Willis failed

to comply with the statutes authorizing his appointment and oath of office. At the time

Wade appeared before the SPGJ, he was not a “duly authorized” special prosecutor because

he had no oath of office on file and was not under a valid employment contract with FCDA.

OCGA Sec. 45-3-8 (“[n]o officer or deputy required by law to take and file the oaths

prescribed in Code Section 45-3-1 shall enter upon the duties of his office without first

taking and filing the same in the proper office.”) Indeed, under Georgia law, Wade had

no more legal authority than any private member of the State Bar of Georgia to even be

present in the grand jury room, let alone serve as the grand jury’s legal advisor.

Wade, however, signed numerous subpoenas for the special purpose grand jury as

a “special prosecutor” with the power of the State to command appearance. Wade obtained

Court orders to compel the attendance of out of state witnesses and to compel witnesses

14
Mr. Roman understands and acknowledges that this issue was raised by other defendants
in prior filings and the Court has rejected the argument in the context of their arguments.
Mr. Roman raises it herein again to show the Court that, standing alone, it may seem like
a technicality, but in the larger context of the various issues surrounding his appointment,
Willis’ lack of authority to appoint him, and the conflict of interest issues addressed below,
the fact that Wade did not file his oath before beginning work takes on new and more
significant meaning and, indeed, constitutes a structural defect in the indictment.

- 20 -
who were asserting privilege or immunity from testifying. Wade negotiated legal immunity

deals on behalf of the State for certain witnesses appearing before the special purpose grand

jury. Wade presented this indictment to a grand jury on behalf of the State of Georgia.

Significantly, Wade has represented to counsel and this Court that he is a duly authorized

special prosecutor, but all of his actions were taken without any statutory legal authority

and while suffering a conflict of interest.

While this issue has been raised and rejected in the context of arugments submitted

by other defendants previously, Mr. Roman reasserts this ground since Wade appeared to

have no more authority than a private citizen invited to participate by the district dttorney

in the proceedings which would render this a structural defect and require dismissal of the

indictment. Olsen v. State, 302 Ga. 288 (2017) made clear that members of a prosecutor’s

staff or an expert witness hired by the district attorney could be present during the grand

jury proceedings, it also clearly stated that its holding did “not mean that prosecutors have

unfettered discretion to invite mere spectators to grand jury proceedings.” Olsen at 291.

Pursuant to O.C.G.A. § 15-18-6, the District Attorney is the legal advisor for the

Grand Jury. The District Attorney is responsible for advising the grand jury on any

questions of law or procedure which it may have as a Grand Jury. In 1973 the Georgia

Supreme Court held that the Grand Jury must rely on the District Attorney for legal advice

and may not employ any other lawyer for that purpose. Daniel v. Yow, 226 Ga. 544 (1970).

Assisting the District Attorney in carrying out these duties will be Assistant District

Attorneys and other employees of his or her office. Mach v. State, 109 Ga. App. 154

(1954); State v. Cook, 172 Ga. App. 433, 440 (1984).

- 21 -
 In this case, Wade was not a member of the district attorney’s staff and was not a

sworn and duly authorized “special assistant” prosecutor. He was present because Willis,

alone, had authorized him to be present despite her not having the legal authority to permit

a member of the public to be present during a secret grand jury proceeding. The statutory

authority Willis relied upon in appointing Wade is clear that such is legal only if “provided

for by local law or . . . authorized by the governing authority of the county.” O.C.G.A. §

15-18-20(a). As noted above, the Georgia Supreme Court has made clear that this

authority is expressly conditioned upon prior approval of the governing authority of the

county. Wilson v. Southerland, 371 S.E.2d 382, 383 (Ga. 1988). Willis had no such

permission. Therefore, Wade was a mere spectator who not only participated, but

significantly influenced the grand jury proceedings in this case.

There are sound reasons why all prosecutors must be sworn and authorized to

perform the public duty of prosecutor. Prosecutors have “the responsibility of a minister of

justice and not simply that of an advocate. This responsibility carries with it specific

obligations to see that the defendant is accorded procedural justice.” See Ga. R. Pro.

Conduct 3.8, cmt. [1]. Indeed, “[t]he prosecutor has more control over life, liberty, and

reputation than any other person in America. His discretion is tremendous. He can have

citizens investigated and, if he is that kind of person, he can have this done to the tune of

public statements and veiled or unveiled intimations.”15 “The prosecutor can order arrests,

15
Robert H. Jackson, U.S. Attorney General, Address at the Second Annual Conference
of United States Attorneys: The Federal Prosecutor (Apr. 1, 1940),
https://www.justice.gov/sites/default/files/ag/legacy/2011/09/16/04-01-1940.pdf.

- 22 -
present cases to the grand jury in secret session, and on the basis of his one-sided

presentation of the facts, can cause the citizen to be indicted and held for trial.”16

Wade asserted such power and control by presenting the case to the special purpose

grand jury, subpoenaing witnesses, granting or denying immunity, negotiating testimony,

seeking arrest warrants, deciding who to include on the indict, deciding what evidence to

present to the grand jury. All of these acts are acts that are only to be entrusted to a person

who is legally authorized to hold such power according to the laws of Georgia and is sworn

under our constitution to fulfil this lawful duty. Wade had no such authorization or power

when he not only was present but ran the grand jury proceedings.17 Mr. Roman, therefore,

respectfully submits that the indictment against Mr. Roman in this matter was obtained

16
Id.
17
Mr. Roman is charged in Count 9 with conspiring to commit impersonating a public
officer by allegedly “conspiring to cause individuals to falsely hold themselves out as the
duly elected and qualified presidential electors…with the intent to mislead …others...into
believing they actually were such officers.” It could be argued that Willis conspired with
Wade to falsely hold himself out as the duly appointed and qualified special prosecutor
from the Fulton County District Attorney’s Office with the intent to mislead witnesses,
grand jurors, court staff, law enforcement, defendants and defense counsel. It could further
be argued that they did so for pecuniary gain in the amounts that Wade has been paid from
taxpayer funds.

Mr. Roman is similarly charged in Count 11 with conspiring to commit forgery in

the first degree for knowingly, with the intent to defraud, make a document other than a
check in such manner that the writing as made purports to have been made by authority of
the duly elected and qualified presidential electors from the State of Georgia, who did not
give such authority and to utter and deliver said document to be filed. It could similarly be
argued that Willis conspired with Wade to knowingly, in with the intent to defraud, make
a document (Wade’s oath of office) other than a check in such manner that the writing as
made purports to have been made by authority of Willis (who did not have such authority)
and that document was uttered and delivered to the clerk for filing.

It could further be argued that they did so for pecuniary gain in the amounts that
Wade has been paid from taxpayer funds and that Willis has enjoyed through her
relationship with Wade.

- 23 -
without legal authority, is structurally and fatally defective and should be dismissed in its

entirety.

II. WILLIS BREACHED HER DUTIES AS A PUBLIC OFFICER AND WILLIS AND
WADE’S PERSONAL, ROMANTIC RELATIONSHIP AND PERSONAL FINANCIAL
INTERESTS IN THE CASE HAS CREATED AN IMPERMISSIBLE,
UNCONSTITUTIONAL CONFLICT OF INTEREST REQUIRING THEIR
DISQUALIFICATION.

A. Willis’ Conflict Of Interest In This Case Violates Mr. Roman’s Right To

Due Process And A Fair Trial Under Both The United States And Georgia
Constitutions.

The Fifth and Fourteenth Amendments to the United States Constitution, Article I,

Section I, Paragraph I and Article VI, Section VIII, Paragraph I of the Georgia Constitution

guarantee under principles of due process Mr. Roman the right to be prosecuted by a

“disinterested” prosecutor. Prosecution by someone with conflicting loyalties “calls into

question the objectivity of those charged with bringing a defendant to judgment.” Younger

v. United States, 481 U.S. 787, 810 (1987)(plurality opinion): As outlined in Younger,

It is a fundamental premise of our society that the state wield it’s formidable
criminal enforcement powers in a rigorously disinterested fashion, for
liberty itself may be at stake in such matters. We have always been sensitive
to the possibility that important actors in the criminal justice system may be
influenced by factors that threaten to compromise the performance of their
duty.

Id.; see generally Berger v. United States, 295 U.S. 78 (1935).

Georgia courts have developed their own standard for disqualification of

prosecutors. In Whitworth v. State, 275 Ga. App. 790, 793, 622 S.E.2d 21 (2005), the Court

recognized a conflict of interest as a ground for disqualification of a district attorney. Such

a conflict of interest has been held to arise where the prosecutor has acquired a personal

interest or stake in the defendant’s conviction. Id. (citing Williams v. State, 258 Ga. 305,

314, 369 S.E.2d 232 (1988)). If the assigned prosecutor has acquired a personal interest or

- 24 -
stake in the conviction, the trial court abuses its discretion in denying a motion to disqualify

him, and the defendant is entitled to a new trial, even without a showing of prejudice. See

Whitworth v. State, 275 Ga.App. 790, 796(1)(d), 622 S.E.2d 21 (2005) (physical precedent

only). See also Young v. United States, 481 U.S. 787, 809–814(III)(B), 107 S.Ct. 2124, 95

L.Ed.2d 740 (1987) (plurality opinion as to Division (III)(B)). See also Amusement Sales

v. State, 316 Ga.App. 727, 730 S.E.2d 430 (2012). Some errors are so fundamental and

pervasive that they require reversal without regard to the facts or circumstances of the

particular case. Delaware v. Van Arsdall, 475 U.S. 673, 681, 106 S.Ct. 1431, 1436, 89

L.Ed.2d 674 (1986).

An error is fundamental if it undermines confidence in the integrity of the criminal

proceeding. Rose v. Clark,478 U.S. 570, 577–578, 106 S.Ct. 3101, 3105–3106, 92 L.Ed.2d

460 (1986); Van Arsdall, supra, 475 U.S., at 681–682, 106 S.Ct., at 1436–1437; Vasquez

v. Hillery, 474 U.S. 254, 263–264, 106 S.Ct. 617, 623–624, 88 L.Ed.2d 598 (1986). “The

appointment of an interested prosecutor raises such doubts.” Young v. U.S. ex rel. Vuitton

et Fils S.A., 481 U.S. 787, 809–10, 107 S. Ct. 2124, 2139, 95 L. Ed. 2d 740 (1987).

“Prosecution by someone with conflicting loyalties calls into question the objectivity of

those charged with bringing a defendant to judgment.” Id. (citing Vasquez, supra, at 263,

106 S.Ct., at 623 (internal quotations omitted)). “It is a fundamental premise of our society

that the state wield its formidable criminal enforcement powers in a rigorously disinterested

fashion, for liberty itself may be at stake in such matters.” Young, 481 U.S. 809-10. “We

have always been sensitive to the possibility that important actors in the criminal justice

system may be influenced by factors that threaten to compromise the performance of their

duty.” Id. As shown below, Willis and Wade are operating under a conflict of interest and

- 25 -
should be disqualified under federal and state constitutional due process grounds because

both of them have acquired a personal interest and stake in Mr. Roman’s conviction, thus

depriving Mr. Roman of his right to a fundamentally fair trial.

B. Willis Breached Her Duties, And Violated Her Oath Of Office, As A

Public Officer By Contracting With Wade And Personally Benefitting
From His Appointment As The Special Prosecutor.

O.C.G.A. § 15-18-2 requires district attorneys in Georgia to take the following oath:

“I do swear that I will faithfully and impartially and without fear, favor, or affection

discharge my duties as district attorney and will take only my lawful compensation. So

help me God.” See also Georgia State Bar Rules and Regulations generally.

Here, Willis violated that oath of office and should be disqualified. Willis has

benefitted substantially and directly, and continues to benefit, from this litigation because

Wade is being paid hundreds of thousands of dollars to prosecute this case on her behalf.

In turn, Wade is taking Willis on, and paying for vacations across the world with money

he is being paid by the Fulton County taxpayers and authorized solely by Willis. As noted

elsewhere, this has happened even though Willis has not sought or obtained Fulton

County’s approval to hire and pay Wade and even though she has never disclosed the

personal nature of her relationship with Wade.

Willis has numerous salaried prosecutors in her office, and more who could have

been hired with her additional Covid backlog funding, who could have prosecuted this

case. Instead, on the day before Wade filed for divorce, she entered into an agreement to

pay Wade far above what any other prosecutor in her office was being paid, and she hid

this agreement from Fulton County, despite Wade being the single biggest expenditure in

her office for professional service contractors for both 2022 and 2023. (Exhibit K)

- 26 -
 Based on the foregoing, Willis and Wade should be disqualified, as well as their

respective offices and firms. See McLaughlin v. Payne, 295 Ga. 609, 612 (2014)(when the

elected district attorney is wholly disqualified from a case, the assistant district attorneys –

whose only power to prosecute a case is derived from the constitutional authority of the

district attorney who appointed them – have no authority to proceed.). See also Georgia

Rule of Professional Conduct 1.10(a)(“While lawyers are associated in a firm, none of

them shall knowingly represent a client when any one of them practicing alone would be

prohibited from doing so by Rules 1.7: Conflict of Interest: General Rule, 1.8 (c): Conflict

of Interest: Prohibited Transactions, 1.9: Former Client or 2.2: Intermediary.”); Rule 1.10,

Comment [1], defining “firm” to include “lawyers in a private firm, and lawyers in the

legal department of a corporation or other organization, or in a legal services organization”

and Comment [2], noting “With respect to the law department of an organization, there is

ordinarily no question that the members of the department constitute a firm within the

meaning of the Georgia Rules of Professional Conduct.”)

C. Willis and Wade Violated Fulton County’s “Code Of Laws” Regarding

Conflicts of Interest.

Fulton County Code of Laws § 2-66 declares it the policy of Fulton County

government that officers such as Willis are:

in fact and in appearance, independent and impartial in the performance of

their official duties; that public service not be used for private gain; and that
there be public confidence in the integrity of the county. Because the
attainment of one or more of these ends is impaired whenever there exists
in fact, or appears to exist, a conflict between the private interests and public
responsibilities of county officers and employees, the public interest
requires that the county protect against such conflicts of interest by
establishing appropriate ethical standards of conduct. It is also essential to
the efficient operation of the county that those persons best qualified be
encouraged to serve in positions of public trust. Accordingly, the standards
hereinafter set forth must be so interpreted and understood as not to

- 27 -
 unreasonably frustrate or impede the desire or inclination to seek and serve
in public office by those persons best qualified to serve. To that end, no
officer or employee of the county, except as otherwise provided by law,
should be denied the opportunity available to all other citizens to acquire
and maintain private, economic and other interests, except where a conflict
of interest situation would necessarily result. The policy and purpose of this
code of ethics, therefore, is to make clear those standards of ethical conduct
that shall be applicable to the persons hereinabove named in the discharge
of their official duties; to implement the objective of protecting the integrity
of the county's government; and to prescribe only such essential restrictions
against conflicts of interest as will not impose unnecessary barriers against
public service.

Fulton County Code of Laws § 2-68(a) addresses “conflicts of interest” and

“impartiality” and requires Officers, such as Willis, to “avoid even the appearance of a

conflict of interest.” An appearance of a conflict of interest exists when a reasonable

person would conclude from the surrounding circumstances that the ability of the officer

or employee to protect the public interest or impartially perform a public duty is

compromised by financial or personal interests in the matter or transaction.” (Id.) Section

(b) further states that:

“[n]o officer or employee shall, by his or her conduct give reasonable basis
for the impression that any person can improperly influence him or her, or
unduly enjoy his or her favor, in the performance of any official acts or
actions.”

Section 2-69 prohibits an officer such as Willis from “directly or indirectly”

receiving a “gift, loan, favor, promise, or thing of value, in any form whatsoever” for

herself from any source “including, without limitation any person or business”, which

Willis knows or should have known is doing business with the county. Section 2-73

governs “nepotism” and subsection (a) would prohibit Willis from employing Wade while

also engaged in a personal relationship with him.

- 28 -
 Here, it is clear that Willis violated the Fulton County laws requiring that she avoid

a conflict of interest in contracting with Wade. First, under Section 2-66, she “in fact and

in appearance”, has violated numerous provisions. She has failed to remain “independent

and impartial in the performance of her official duties” because she specifically awarded

lucrative contracts to her boyfriend, from which she now benefits financially through

personal trips, hotel rooms, and the like paid for by Wade. See id.

Second, she has used her public service for private gain, i.e., by giving Wade the

lucrative contracts as the special prosecutor on this case, she now is able to use those

monies for personal trips and expenses in violation of Fulton County’s Code of Laws. See

id. This completely undermines “public confidence in the integrity of the county.” See id.

Indeed, this situation presents exactly the situation Section 2-66 contemplates, “a conflict

between the private interests [of Willis and Wade] and the public responsibilities of [Willis

and Wade]”. See id. When such a conflict exists, Fulton County has established

“appropriate ethical standards of conduct”, see id., which Willis and Wade here have

violated.

Third, Willis also violated Section 2-66, because she failed to appoint a person “best

qualified” for the position. As noted above, there are numerous lawyers in the City of

Atlanta and across the State of Georgia with ample experience prosecuting and defending

felony RICO cases, yet Willis chose to appoint her boyfriend, who has little to no

experience trying felony cases, much less complex RICO actions. Put into context, it is

clear that Willis did this, not because Wade was the most or even generally qualified, but

because she wanted herself and Wade to enjoy financial gain from his relationship with

- 29 -
Willis and she had the power to make that happen, though she never obtained the authority

from Fulton County to do so.

Fourth, while Mr. Roman submits that there is an irreparable conflict of interest in

Wade’s appointment, there can be no doubt that Willis’ action in appointing Wade fails to

“avoid even the appearance of a conflict of interest” under the Fulton County Laws. See §

2-68(a). In light of Willis’ personal relationship with Wade both before and after his

appointment, no reasonable person could conclude from the surrounding circumstances

that Willis or Wade would be able “to protect the public interest or impartially perform a

public duty” when they both were obviously “compromised by financial or personal

interests in the matter or transaction.” See id. Indeed, the personal and financial conflict

of interest here between Willis and Wade strikes at the whole purpose of Fulton County’s

conflict of interest rules and undermines public confidence in the ability of Willis and

Wade to discharge their duties impartially and without self-interest or gain.

Fifth, Willis’ work in this case relates exclusively to Fulton County, so her ability

through her personal relationship and trips with Wade to enjoy the financial gain of her

decision to appoint him violates Section 2-69. In other words, Willis “directly or

indirectly” received a “gift, loan, favor, promise, or thing of value, …” for herself from her

payments to Wade. See Id. Likewise, she has violated Section 2-73, designed to prevent

“nepotism”, because she has employed him (or, at the very least paid him) while also

engaged in a personal relationship with him. See id.

Finally, the Fulton County Code of Laws § 102-464 states that “it shall be a breach

of ethical standards” for Willis to contract with Wade when Willis knew she had a financial

interest, by virtue of her personal relationship with Wade, in contracting with Wade. Under

- 30 -
Fulton County Code of Laws, this would be considered a conflict of interest and require

Willis to “promptly submit a written statement of disqualification and shall withdraw from

further participation in the transaction involved.” (Id.) Section 102-466(a) also states that

“[i]t shall be unethical for any person to …give any employee ….a gratuity ….in

connection with … a contract.”

The meaning of all of this is simple; Willis violated her own county’s ethical

standards and created an impermissible conflict of interest when she contracted with Wade

knowing full well she had a personal and financial interest in the appointment, particularly

since she never disclosed her relationship with Wade to Fulton County and never obtained

Fulton County’s approval prior to appointing him. See Id., § 102-464. As the Fulton

County Laws make clear, under those circumstances, Willis was laboring under a conflict

of interest, which required her to “promptly submit a written statement of disqualification

and shall withdraw from further participation in the transaction involved.” (Id.). Obviously

knowing she wanted to continue prosecuting this case, Willis did not make any such

disclosure and has not withdrawn from her representation of the State in this matter even

though she is prevented from doing so. Accordingly, based on the conflict of interest in

this case that cannot be avoided or fixed, Mr. Roman respectfully requests that both Willis

and Wade, and their respective offices and firms, be disqualified from any further

involvement in this matter.

D. Willis and Wade Have Violated The Rules of Professional Conduct Regarding
Conflicts Of Interest.

Under the Georgia Rules of Professional Conduct, “[a] lawyer shall not represent

or continue to represent a client if there is a significant risk that the lawyer's own interests

or the lawyer's duties to another client, a former client, or a third person will materially

- 31 -
and adversely affect the representation of the client, except as permitted in (b). Georgia

Rule of Professional Conduct 1.7(a), “Conflict of Interest: General Rule” (emphasis

added). Subsection (b) of Rule 1.7 provides:

“If client informed consent is permissible a lawyer may represent a client

notwithstanding a significant risk of material and adverse effect if each
affected client or former client gives informed consent, confirmed in
writing, to the representation after:

1. consultation with the lawyer, pursuant to Rule 1.0 (c);

2. having received in writing reasonable and adequate information

about the material risks of and reasonable available alternatives to
the representation, and

3. having been given the opportunity to consult with independent

counsel.”

Id. Subsection (c) provides that:

“Client informed consent is not permissible if the representation:

1. is prohibited by law or these rules;

2. includes the assertion of a claim by one client against another client

represented by the lawyer in the same or substantially related
proceeding; or

3. involves circumstances rendering it reasonably unlikely that the lawyer

will be able to provide adequate representation to one or more of the
affected clients.”

“Loyalty to a client is impaired when a lawyer cannot consider, recommend or carry

out an appropriate course of action for the client because of the lawyer's other competing

responsibilities or interests.” Rule 1.7, Comment [2]. “If an impermissible conflict arises

after representation has been undertaken, the lawyer should withdraw from the

representation.” Id., Comment [3] (citing Rule 1.16). “The lawyer's personal or economic

interests should not be permitted to have an adverse effect on representation of a client.”

- 32 -
Id. Comment [6]. “If the propriety of a lawyer's own conduct in a transaction is in serious

question, it may be difficult or impossible for the lawyer to give a client objective advice.”

Id. “A lawyer may not allow related business interests to affect representation, for

example, by referring clients to an enterprise in which the lawyer has an undisclosed

interest.” Id.

Rule 1.8(j) provides that, “[a] lawyer shall not acquire a proprietary interest in the

cause of action or subject matter of litigation the lawyer is conducting for a client, except

that the lawyer may:

1. acquire a lien granted by law to secure the lawyer's fees or expenses

as long as the exercise of the lien is not prejudicial to the client with
respect to the subject of the representation; and

2. contract with a client for a reasonable contingent fee in a civil case,

except as prohibited by Rule 1.5.”

Id. “Paragraph (j) states the traditional general rule that lawyers are prohibited from

acquiring a proprietary interest in litigation.” Id., Comment [10].

Rule 8.4(a)(4) of the Georgia Rules of Professional conduct prohibits a lawyer from

engaging in conduct that involves dishonesty, fraud, deceit or misrepresentation. The

American Bar Association, Standards of Criminal Justice, 3-2.1(c) provides when the

appointment of a special prosecutor from outside the office is required on a particular

matter, such special prosecutor “who has a personal or financial interest in the prosecution

of particular charges …. Should not be permitted to serve as prosecutor in that matter.”

Disqualification of the district attorney is proper when the prosecutor has acquired a

personal interest or stake in the defendant’s conviction. See Whitworth v. State, 275 Ga.

App. 790, 793, 622 S.E.2d 21 (2005); Williams v. State, 258 Ga. 305, 314, 369 S.E.2d 232

- 33 -
(1988).18

Applying these principles here, both Willis and Wade are laboring under a conflict

of interest that violates Mr. Roman’s constitutional right to due process and fair trial and

violates the Rules of Professional Conduct. First, both have acquired a personal financial

interest in Mr. Roman’s conviction. Wade has personally and financially benefitted from

his personal relationship with Willis since he has received lucrative amounts under his

continued contracts with Willis. He will continue to be incentivized to prosecute this case

based on his personal and financial motives, so he has acquired a unique and personal

interest or stake in Mr. Roman’s continued prosecution. That is, he is motivated to

prosecute Mr. Roman for as long as possible because he will continue to make exorbitant

sums of money.

Likewise, Willis has created a system where she receives indirect personal and

financial benefits (i.e., trips, hotel stays, and other benefits) from Wade due to her awarding

him the contracts to be a special prosecutor. While she is not paying herself directly, she

nonetheless reaps the rewards from the funds due to her personal relationship with Wade

and, thus, has also acquired a personal interest and stake in Mr. Roman’s continued

18
It is worth noting, though not the focus of the instant Motion, that Willis has been on
numerous national media outlets discussing the instant case. If it continues, Mr. Roman
will have no choice but to file a motion to prevent her from continuing to make such
statements under Georgia Rule of Professional Conduct Rule 3.8(g), “Special
Responsibilities of A Prosecutor”, which provides that Willis should, “except for
statements that are necessary to inform the public of the nature and extent of the
prosecutor's action and that serve a legitimate law enforcement purpose, refrain from
making extrajudicial comments that have a substantial likelihood of heightening public
condemnation of the accused. There is no doubt that some of the statements she has made
publicly were designed to condemn Mr. Roman and others before trial begins. It threatens
to poison the jury pool, and Mr. Roman intends to act with additional motions if it
continues.

- 34 -
prosecution. Accordingly, they both have deprived Mr. Roman of his due process and fair

trial rights under the United States and Georgia Constitutions and they should be

disqualified. See Whitworth v. State, 275 Ga. App. 790, 793, 622 S.E.2d 21 (2005);

Williams v. State, 258 Ga. 305, 314, 369 S.E.2d 232 (1988).

Similarly, they both suffer and labor under now unavoidable conflicts of interest

that violate the Rules of Professional Conduct. Under Rule 1.7, Willis and Wade both

cannot continue to represent the State of Georgia or Fulton County in this matter because

there is a “significant risk that the [Willis and Wade’s] own interests or [Willis’] duties . .

. [Wade] will materially and adversely affect the representation….” (See id). of the client,

except as permitted in (b). Willis and Wade have both a personal and financial stake in

this litigation and in the prosecution of Mr. Roman specifically and given their personal

and financial relationship with each other, there can be no doubt that the relationship Willis

has with Wade (a “third party”) under Rule 1.7, will materially and adversely affect Willis’

representation in this matter.19 Rule 1.7 contemplates that under such circumstances, Willis

and Wade must withdraw from representation. Id., Comment [3] (citing Rule 1.16).

Likewise, it is clear that “[Willis and Wade’s] personal or economic interests should not

be permitted to have an adverse effect on representation of a client.” Id. Comment [6].

Due to their receipt of county money and use of that for their personal relationship,

Willis and Wade have also acquired a propriety interest in the instant prosecution and have,

therefore, violated Rule 1.8(j). See id. (“[a] lawyer shall not acquire a proprietary interest

19
There has been no evidence that Willis or Wade disclosed the potential conflict to either
the State of Georgia or Fulton County, Georgia in any manner, so the exceptions set forth
in Rule 1.7(b) and (c) following informed consent do not apply.

- 35 -
in the cause of action or subject matter of litigation the lawyer is conducting for a client, .

. .”), Comment [10]

Finally, Willis and Wade have hidden the nature of their personal relationship from

both the State of Georgia, Fulton County and the defendants in this matter and failed to

disclose the financial compensation from which they both benefit as a result of Wade’s

appointment as a special prosecutor. This arguably would constitute a misrepresentation

in violation of Rule 8.4(a)(4) of the Georgia Rules of Professional Conduct and require

disqualification. This is in keeping with The American Bar Association, Standards of

Criminal Justice, 3-2.1(c), which provides that Willis’ appointment of Wade is improper

when he “has a personal or financial interest in the prosecution of particular charges. See

id.

III. WILLIS MAY HAVE VIOLATED 18 U.S.C. § 1346, THE FEDERAL RICO STATUTE
BY FAILING TO DISCLOSE HER CONFLICT OF INTEREST.

The district attorney’s apparent intentional failure to disclose her conflict of interest

to Fulton County and the Court, combined with her decision to employ the special

prosecutor based on her own personal interests may well be an act to defraud the public of

honest services since the district attorney “personally benefitted from an undisclosed

conflict of interest” which is a crime under 18 U.S.C. § 1346 as well as a predicate act

which could result in a RICO charge against both the district attorney and the special

prosecutor.

Willis has failed to disclose this conflict of interest which resulted in her own

personal gain, i.e., vacations paid for by the Law Offices of Nathan Wade. Honest services

fraud is a crime defined in 18 U.S.C. § 1346 which includes public sector honest service

fraud by a public official failing to disclose a conflict of interest resulting in person gain to

- 36 -
that official. Prosecutions under the federal Racketeer Influenced and Corrupt

Organizations Act (“RICO”) frequently use violations of the honest services statute as

predicate acts of racketeering. As such, two direct deposits or mailed checks into Wade’s

account by Fulton County would constitute two transmissions in the execution of honest

services fraud that could form “a pattern of racketeering activity.”

The irony that Willis and Wade engaged in a pattern of racketeering that could be

charged in a federal RICO indictment is not lost here. Indeed, prosecutors have highly

favored using this law, much like the State of Georgia has enjoyed using the state RICO

charge, because the statute is vague enough to be applied to corrupt public officials’

unethical activities when they do not squarely fall into another specific category such as

bribery or extortion. If a government official makes an official decision, such as the

employment of Wade, based on their own personal interests or personally benefits from an

undisclosed conflict of interest, that official has defrauded the public of their honest

services. United States v. Lopez-Lukis, 102 F.3d 1164 (11th Circ. 1997).

As explained in Lopez-Lukis, “[t]he crux of this theory is that when a political

official uses his office for personal gain, he deprives his constituents of their right to have

him perform his official duties in their best interest. Elected officials generally owe a

fiduciary duty to the electorate.” Id. at 1169. When a government official, such as Willis,

personally benefits from an undisclosed conflict of interest, like she has from her

employment of Wade, she has defrauded the public of her honest services. See United

States v. Sawyer, 85 F.3d 713, 724 (1st Cir. 1996) (“The cases in which a deprivation of an

official’s honest services is found typically involve either bribery of the official or her

failure to disclose a conflict of interest, resulting in personal gain.”). See also United States

- 37 -
v. Langford, 647 F.3d 1309 (11th Cir. 2011)(Honest services mail fraud may be proved

through the defendant’s non-action or non-disclosure of material facts intended to create a

false and fraudulent representation.)

In Langford, a county commissioner was convicted of defrauding the public of his

honest services by accepting gifts of clothing and jewelry which he did not disclose to the

public or his county from the banking firm he awarded the contract to perform county work.

Defendant was conferred with public authority to choose who would be awarded the public

contract and chose a firm which provided him with gifts. His failure to disclose this fact

along with the use of mails and wires for the contracted firm to be paid (much like Wade

was paid through use of the banking system) constituted sufficient evidence of honest

services fraud.

It is not our intention here to find ways to prosecute the prosecutor, but it must be

brought to the attention of the Court that the actions of the two lead district attorneys in

this case arguably constitute crimes under federal law.

CONCLUSION

For all of the foregoing reasons, Mr. Roman respectfully requests that this

Honorable Court grant the instant motions, dismiss the indictment against Mr. Roman, and

disqualify Willis, Wade and their respective offices and firms from any participating in this

matter any further.

Respectfully submitted this 8th day of January, 2024.

THE MERCHANT LAW FIRM, P.C.

/s/ Ashleigh B. Merchant

ASHLEIGH B. MERCHANT
Georgia Bar No. 040474

- 38 -
239.
 IN THE SUPERIOR COURT OF FULTON COUNTY
STATEOF GEORGIA
STATE OF GEORGIA, )
)
v ) INDICTMENT NO.
) 235CI88947
MICHAEL A. ROMAN, )
)
Defendant. )
0)
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within and foregoing
DEFENDANT MICHAEL ROMAN'S MOTION TO DISMISS GRAND JURY
INDICTMENTAS FATALLY DEFECTIVE AND MOTION TO DISQUALIFY THE
DISTRICT ATTORNEY, HER OFFICE AND THE SPECIAL PROSECUTOR FROM
FURTHER PROSECUTING THIS MATTER has been served upon counsel for the State
of Georgia by filing same with the Court's electronic fling system, which will delivera
copy by e-mail to the following counsel of record for the State:
Nathan Wade
I
Anna Cross
I
John Flovd

Daysha Young
I
Adam Ney
I
Alex Bemick
I
F. McDonald Wakeford

Grant Rood

-40-
 John W. Wooten

1 further certify that, in compliance with Judge Scott MeAfee’s Standing Order a
copy of this pleading has been emailed to the Court via the Litigation Manager Cheryl
Vortice at Cheryl.vortice@jultoncountyga gov with copies of such communication
provided to all counselofrecord for the State a the email addresses provided above.
This 8% day of January, 2024.
THE MERCHANT LAW FIRM, P.C.
(s/ Ashleigh B. Merchant
ASHLEIGH B. MERCHANT
Georgia Bar No. 040474

a1.
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EXHIBIT C
 1 A RESOLUTION AUTHORIZING FUNDING FOR ADDITIONAL PERSONNEL FOR
2 THE OFFICE OF THE FULTON COUNTY DISTRICT ATTORNEY PERSONNEL

3 WHEREAS, Fulton County is committed to the public safety of all citizens;

4 WHEREAS, felonious crime in Fulton County has increased significantly, causing

5 Fulton County residents to feel less safe;

6 WHEREAS, the Fulton County District Attorney's Office (the "DA's Office") is

7 responsible for investigating and prosecuting violations of criminal statutes within Fulton
8 County; and

9 WHEREAS, as a result of the COVID-19 pandemic, an historic backlog of cases

10 maintained by the Office of the Fulton County District Attorney and the current high crime
11 rate, there is currently a significant backlog of criminal cases in the Superior Court of
12 Fulton County, Georgia; and

13 WHEREAS, in order to timely investigate and prosecute these backlogged criminal

14 cases and respond adequately to the increased crime rate and increased number of
15 cases received, the DA's Office must increase personnel immediately; and

16 WHEREAS, the DA's Office needs an additional fifty-five (55) employees to begin
17 working between November 2021 and December 2021:

18 WHEREAS, these additional fifty-five (55) employees, not including current

19 permanent, seasonal or temporary staff, are ten ADA IVs, ten ADA Ills, fifteen Senior
20 Investigators, five Community Resource Specialists, an IT Specialist, seventeen Legal
21 Assistants and two Victim Witness Advocates that are immediately needed for the DA's
22 Office to respond to its increased criminal case load;

23 WHEREAS, thirty-seven (37) of the fifty-five (55) employees will likely be hired and
24 on-boarded on November 8, 2021, receiving four (4) pay-outs for CY 2021 and the
25 remaining eighteen (18) employees will likely be hired and on-boarded on December 8,
26 2021.
 1 WHEREAS, the fifty-five (55) new employees who will be hired, in November 2021
2 and December 2021, will receive total compensation not to exceed $780,621.84 in CY
3 2021;

4 WHEREAS, the additional fifty-five (55) employees will provide the DA's Office

5 with the personnel resources to adequately respond to the increased crime rate and

6 resulting increased case load:

7 NOW, THEREFORE, BE IT RESOLVED, that the Board of Commissioners hereby

8 approves and authorizes additional personnel funding for the Office of the Fulton County
9 District Attorney.

10 BE IT FURTHER RESOLVED, that the Board of Commissioners hereby directs

11 and authorizes the County Manager and Chief Financial Officer to add additional
12 personnel funding, for CY 2021, in the amount of $780,621.84 to be used by the Office of
13 the Fulton County District Attorney for these personnel needs.

14 BE IT FURTHER RESOLVED, that the Board of Commissioners hereby directs

15 and authorizes additional personnel funding, for CY 2022, not to exceed $5,000,000.00
16 to be used by the Office of the Fulton County District Attorney for these personnel needs.

17 BE IT FINALLY RESOLVED, that this Resolution shall become effective upon its
18 adoption, and that all resolutions and parts of resolutions in conflict with this Resolution
19 are hereby repealed to the extent of the conflict.

20 PASSED AND ADOPTED by the Board of Commissioners of Fulton County,

21 Georgia, this 15!" day of September, 2021.

22 FULTON COUNTY BOARD OF COMMISSIONERS

23
24
>
25 "<
26 Robert L. Pitts
27 Chairman
28
29
30

2
mEM# AL-CCF! pcs
RECESS MEFTING
 1 ATTEST: :
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2
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4 Tonya R: Grier
5 Clerk to the Commission
6
7
8
9
10 APPROVED AS TO FORM:
1i
12
13
14 Kave Woodard Burwell
is Interim County Attorney
16

3
ITEM
YERECS
# 20-601 Res7 iS; 2-1
EXHIBIT D
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EXHIBIT E
 PROFESSIONAL SERVICES AGREEMENT BETWEEN THE FULTON COUNTY
DISTRICT ATTORNEY'S OFFICE AND NATHAN WADE, P.C.

THIS ADDENDUM amends the contract between the FULTON COUNTY DISTRICT
ATTORNEY'S OFFICE, (hereinafter "FCDA" whose mailing address is 136
Pryor Street,
Atlanta, GA 30303 and NATHAN WADE, P.C. (hereinafter ""Atto
rney").
WITNESSETH:
WHEREAS, FCDA and Attorney entered into and executed a contract dated November
1, 2021
(hereinafter "Agreement").

WHEREAS, the scope of service for that Agreement is from November 1, 2021 thru October
31, 2022.

WHEREAS, Agreement states, "any modification to agreement will be effective only if it is in

writing and signed by the party charged."

SECTION 1: Addendum to Agree

ment
In the manner outlined in Agreement FCDA writes
, to modify the original contract as follows:
Section 1.1: Attorney will pre-pay any travel or
lodging cost associated with the performance of
duties outlined in Agreement.

Section 1.2: All travel and lodging arran

gements must be pre-approved by Deputy of
Operations, Dexter Q. Bond, Jr. After approval is grante travel and
shall be booked in accordance with the Fulton
d, lodging cost and lodging
County'stravel policy.
Section 1.3: Receipts for travel and
lodging must be submitted to FCDA with the succeeding
monthly invoice. (If pre-approved travel is comp
leted in April 2022, all travel receipts and
lodging receipts shall be submitted to FFCDA with May 2022
invoice).

The validity of this modification to

agreement and its terms and provisions as well as the
and duties of the parties of the Agreement shall be rights
governed by the law of the State of Georgia.
The Agreement with this Addendum to
Agreement represent the complete and accurate scope of
services between + FCDA and
Attorney. Any additional modifications to Agreement or
Addendum must be written in a
separate correspondence and signed by the both partie
s.
IN WITNESS WHEREOE, The parties have execu
5 ted this Agreement on the dates indicated
their res tive names: by

strict Attorney Fani T. Wiilis Date Nathan Wade, P.C, Attorney Consultant Date
EXHIBIT F
 LAW OFFICES OF NATHAN J WADE
VENDOR 107 50000076035
ATTENTION: Futon County Disirct Atm’ Ofce
13 Pryor sees INVOICE #1
Adar, GA 30363
Project Tie: Ant Corruption Special Prosecutor [|]

Terms: 0085s —
rm TREE
#3I
Conse onpre cman 1321 Shs @s250 5200000
Corton sows
Preparedcasesforprovial wea ums@so sow
memoran —
of iwconcerning wien amas so
cm
rsacuton of case
[r—— wa ans stoma
a
Meatng winpoten winesses 111521 8s@ st00
EH
Consutes unt sraprovdes 11721
Iegaopmowin
n oncave hours
a 5100000
Read andRoview cose summa11/1821
ries Bhs @S50 5200000
[— "021 nous srs000
ex

Taal s1500000
[okaytopay |
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are
6 |
Submited, ths dayer = 2022

Nava n
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_—
 LAW OFFICES OF NATHAN J WADE
VENDOR ID# 0000076036
ATTENTION. Futon County District Atoney's Office
136 Pryor Street INVOICE #2
Atanta, GA 30303
Project Title: Anti-Corruption Special Prosecutor [

Terms: 30 Days
EE CT
ECCT
E0
Read and Research investgaive 12121 Bhs@S250 5200000
materials
Consult re preindictmissues
ent 12321 10hs@250 $2500.00
concerning ant corruption cases
Reviewand discusspolicy 12821 8s @250 5200000
Meetingwih unt 12821 ahous $1.00000
@250
Discuss appicaton of Georgia ~~ 121021 6s @ $1.50000
States 5250
Locate and consult wihexpert 121321 7hours 175000
@250
Read and Review case summaries 121421 8s @S250 5200000
Meeting wih unit 121621 4hours 1.00000
@20
Organize legal srategy and prepare 122021 vs @250 $125000
for fture incicment
00000
Total 515.0000
-_— OO oo
[okay To pay
Submited, ins 5” day of January 2022 ATG |
- ee

Nathan
JWade

_
 LAW OFFICES OF NATHAN J WADE
VEID# ND vS2000OR
076006
ATTENTION: Fulton Gury istrict Atornays Ofice
136 Pryor Street
Atart, GA 30303 INVOICE #3
ProjectTite: Anti-Corruption Special Prosecutor
[
Terms: 30 Days
Doscription ATE HOURS Cost
EE
©
Rea an Resarch momo M02 emeeszso s200000
View vos anc anices or mestog 11122 Tha@2so $1500
TeamConference vie emseao seooc0
Toa proc andmestngWinOA 11322 7huss $1.75000
250
Propewiess nteniowschecde 11422 rvs $1.00000
<5
Ustentoroves ancwiness 11822 7 rors $1.75000
Swaments 2%
Oderof merv andowcuestasns 11922 ons ses $150000
Rese and Gocume
ar ch
ntDrat ing 12022 8 hues 200000
2%
Toammestng maga satin 12422 swsezs $2500
—_— ou
ew Soom
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Submited hs 1_day of Fema 2022 BYarg
Natran ade

_—
 LAW OFFICES OF NATHAN JWA
VENDOR 04 VS0000076036 DE

ATTENTION: Futon Coury trict Attorney's Of

198 Pr Sen INVOICE #4

Toms: 300s —_—

Description ATE HOURS Gost
ot
5 i
Mootng app forwinss 2122 8ws@szs0 | 200000
Meetwaievonwinessss 2222 amsozs0 $1o0000
TonGoveocemimestng 2322 smsazso 125000

semen, waren meetng. 02 S30 se

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ET
 LAW OFFICES OF NATHAN J WADE Se
VENDO [08VS000007603%
R
ATTENTION: Futon Coty Dic Atma Offco
138 Pryor Street INVOICE #5
Atent, GA30200
Prfct Ti: An ComptonSpecsProsecdcx
nn A
FARE —_——
&
Vootig wagep fries
oon STZ Beg200000
Vootwaineriouwinessss 0% Beez 5200000
Team Contecomameaing, S22 The@20 8175000
mostigaion
vivesss an aren of
Winess ions wee shou s125000
50
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{esenonyana oven vars 3722 she
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Team Meatig sdvesigaion 3822 hours S200
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Toamsiatogicmostng nF 10M 20Ne@20 500000
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ervewviess ndpepmeno 32122 Shows 200000
om
Tenens corer wives
tanious 9229240 24070 $0000
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"Duetobiing restrictions thisinvoicehasbeen significantly truncated ATG
Submited, ths_31cay ofMach, 2022
Nathan Jwade
 LAW OFFICES OF NATHAN J WADE
VENDOR IDs VS0000076036
ATTENTION: FutonCountyDistrict Atorey’sOffce
136Pryor Stree
Atants, GA 303 INVOICE #6
Project Ti: An Compton Special Prosecutor [|
Description ONE HOURS Cost ——
TER
5
Winess itervew wz ansess0 7000
Travou of Seand intoriew 4/4/22-4/5 20s G25 $5.00000
2
Team Moetng wFoyd 22a ims20 $3500

Team me ting and wines vee sma $125000

Team interv andinesiew
tgaton 41322 Shows s20000
a2
Wines Interviews Sout Geog 4/1422 Bours 5200000
az
Winess itenjews Sou Geoga 41522 8s@250 200000
Team meeting; Cont win 1824 24MsG250 3600000
Research oga 5516s 0 prop tery 21/22
Research; Crating, wines 422122-4/ 21 pours 55.2500
—_revs 2
w= ewGos
Travel outofState nervew and. 427/22.4/ 167vs 6250 S7000.00
Resoarcn
-_ 2
we
-_—
To S750 SE .

Nathan J Wade

-_—
 LAW OFFICES OF NATHAN J WADE
VENDOR D# VS0000076008
ATTENTION Futon Gury Dirt Aton’Ofice
156 Pryor Steet INVOICE #7
Aart GA 50303
Project Tite: Anti-Corruption Special Prosecutor Reimbursement

Description DATE HOURS Gost —

PAE
©
Puchasaion Dota vines 52022 S1.2%019
User and Pubic Tarsporaion 416/22 ss245
Food curing rave wz swt
Magra Hot azz soz
Arpor Pare wz smo
Purchase gn Dota Arnos 42322 srs20
Uoer anc Tasporaion 412822 ss176
Foodrng ave waezz serie
Hat PaceHoe pr stiosa

Suita, is 29 cayof _Apr, 2022

Natran J vice

-_—
 CapitalOnc
Posted Transactions Since Your Last Statement Account Ending in ...2asg@

DATE DESCRIPTION CATEGORY CARD AMOUNT

Apr 07 ABM Parking Gas/Automative Nathan W. $38.00

2144

Apr 07 Magnolia Hotel Denver, A Lodging Nathan W. $301.26

Tribute Hotel 2 144

Apr 07 Thirsty Lion Gastropub & Dining Nathan W. $42.65

Grill 21 144

Apr 07 Smashburger Dining Nathan W. $15.53

2144

Apr 06 Uber Technologies Other Travel Nathan W. $34.97

we 44

Apr 06 Uber Technologies Other Travel Nathan W. $6.99

2144

Apr 06 RTD EAST DIA Other Travel Nathan W. $10.50

21 44

Apr 06 Delta Air Lines Airfare Nathan W. $2.00

2144

Mar 28 Delta Air Lines Airfare Nathan W. $1,213.20

21 44

Mar 28 Delta Air Lines Airfare Nathan W. $14.99

Capital One 4/29/22, :53 PM

4
Ca One
Posted Transactions Since Your Last Statement Account Ending in ...

DATE DESCRIPTION CATEGORY CARD AMOUNT

Apr 28 Uber Technologies Other Travel Nathan W. $27.13

2144

Apr 23 Delta Air Lines Airfare Nathan W. $757.20

2144

Nathan W.
wt 144

Total:

https://imyaccounts.capitalone.com/Card/w+lBOaBExPxYvNkhmhncJgl23BOrsZcw6OrZKbEOW2Qz/priniTransactiansMadal Page Tof 1

 Capital One 4/29j22, 1-52 PM

Capital
Pending Transactions Account Ending in ...@o4eo

DATE DESCRIPTION CATEGORY CARD AMOUNT

Pending Hank's Oyster Bar Dining Nathan W. $130.00

2144

Pending TST* BOARDWALK -WHARF Dining Nathan W. $130.90

21 44

Pending ATLANTAINTL AIRPORT Gas/Automotive Nathan W. $47.00

ADV 2144

Pending THE GROVE-WASHINGTON Dining Nathan W. $10.22

2144

Pending Uber Technologies Other Travel Nathan W. $4.10

2144

Pending Uber Technologies Other Travel Nathan W. $20.53

2144

eum,

Pending Hyatt Place Lodging Nathan W. -$719.34

2144

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ncJgi23BOréZcw6OrZKbEOWzQ=/printTransactionsModal Page 1of 2
 Capital One
4[29/22, 1:52 PM

Pending Hyatt Place Lodging Nathan W. $719.34

2144

Total:

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Page 2 of 2
 LAW OFFICES OF NATHAN J WADE
VENOOR 04VSco0007600 o
ATTENTION: Futon County District Attorney's Office.
52 Pryor Ste INve
INVOICE
ProcTl: Art Coruptn Spec Prosecutor
Deseripon DATE HOURS cost _____]
RTE
5
Sokct SPC) S222 mses S000

Cot appeararc 0 9G 2 2s

Resear eam mesings. wines 2626 9250

Rovew Subpoena:Contuth 52722 sse2s0 s200000
Team moot; Confwn 6, PG 53122 Bs 0250 5200000
-_— 000000
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BE —

-—
 LAW OFFICES OF NATHAN J WADE
VENDOR D#vS0000076038
ATTENTION:Futon ounyDistt AtayOfc
50 orSet INVOICE #9
porean:
Prt Tie: AnCoruption Spec Prsecor
Description ETE
Fro EE
ES
GPG
wvTeamrovowoltoatmory | @vzz
oh | emToms 400000
TouMostngs
Toons PropandSchoo 6022 6hs@zs0 S20000
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Weotrgwiv uigeRenin |wiote
fy aha Samm
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Posada potr oz
hs aime 3900000
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Oa water rvow/roaren wi7zz ovens Sanm
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SPaay spon Atomepsre 02vzz- senows 360000
Sve as
Wootrguan estates wsoico 02422 51s 0080 $128000
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Naan ace
 LAW OFFICES OF NATHAN J WADE
VENDOR 108VS0000076036
ATTENTION: Futon County Distt Atormey'sOffs
108Pryor See INVOICE #10
Atari GA50003
Project Tie: AntCoupon Special Prosar
Description DATE
[HOURS | Cost |__|
rei
E
WolontoQuash
rsncpencout; 7/22 | Shs@Szs0. $200000
Review
vs Discover Moting wihop 7/522. 32s@250 $8,000.00
Pome
Homa r pe Tas
weatwinopatmrowines ree Tween | sta
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SPosmeangown aes 7222 bows $8000
fbi opens LALGl rs
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SPO Matonto Recuse/ scully 7/1922. zona $5:00000
Teves ax
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vitenResoach prop or Fed, 3922 4 nurs
a5 $1.00000
Toam stag mesg Faton 72522 mhaozso 2.00000
SPO:
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Review charges ovedsconry. 72722. tohouws | 8400000
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Prone cont wihopay rove 72922 Bm Gd0 | S20m0
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Submit, is_20 doyof uy 2022
Nathan
JWace
 LAW OFFICES OF NATHAN J WADE
VENDOR 0# V500000760
ATTENTION: Fulon oun Dstt Atom’ Ofco
106Pryor Set INVOICE #11
Alara, GA50003
ES —
Description
FAA ETE ——
&
Teun Mootootrgsro
Ivesgaton; Dscovey veiw 8/22.
5322 24sas 5800000
Hearings
Diconaywih Goutroviewccs: 8422. 12ws@250 53,0000
das 5%
FodGouthaungs uyHoang: 0922. a6maaaso $6500
SPO; Dacovay, Gani dots 352
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ss
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ava 82.8000
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Aomeypponecontoronces: 82022.
vow rp tomer waves sns@zso 52.0000
POL Cont Howngro testimony 62522 ha02s0 $2000
Review
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Submitted, this 31st day of August, 2022 ATG i
Nathan ico
 LAW OFFICES OF NATHAN J WADE
VENDOR ID# VS0000076036
ATTENTION: Futon County DistrictAtorey'sOffce
136PryorStreet INVOICE #12
Atanta, GA 30003
Project Tie: Anti-Corruption Special Prosecutor I
Description DATE [HOURS | Cost |_|]
COMPLET| BILLED
5
SPO, ntervow wih ector, 0/1/22 Bhs@S250 S2000.00
negotiations wih OA
Oscovey, imerviow winesses ~~ 9222 8hs@250 S2.00000
SPGUconfWinOAretesimony 9622 7hs@250 $1,750.00
Wines iniervows: conf cal DG; 97/22. 24 hows $6,000.00
team meatng 9822 G20
Research and Roviow transarpt 9/1222 Svs@ 200000
testimony to prep for winess test 5250
PG and Team Meetings 91322 26hous $6,000.00
91522 @2s0
Travel 10 meet wit OA prop forest 9/1622 5 hours $125000
6250
Team strategic meetng andFoyd 91922 Bhs@250 82.0000
meeting
PG: conf wih cout 92022. 16Ms@250 $4,000.00
92122
Review Disc docs: team brain rin 9/22/22- 9 hours 225000
———————— mage 92y22__ a250
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Disc ont;PO meetingsmeee aeaze
PG; Toam Review and eed]
expeciations 9292 Tihows@ | $275000
ye fo next steps 9022 250
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Due to bing estctons his voicehasbeen sgniicanty roncated
Submited, this 30 day of September, 2022 [ray opy
Nathan J Wade bra “|
 LAW OFFICES OF NATHAN J WADE
VENDOR D# VS0000076036
ATTENTION: Futon County District Attorney's Office
136PryorStreet INVOICE #13
Atanta, GA 30303
Project Tit: Ant-Cormuption Special Prosecutor I
Description DATE HOURS | Cost —_—
COMPLET|BILLED
0
Toam research meeting, prep 10/4/22. 28 hrs 7.00000
warrants,negotiations wih OA 10/6/22 @5250
Hearing, meet with OAre motions 10/7/22 3s 8250 75000
and procedure re open court
arguments
Procedural prop; Discovery: 101022 71s @250 $0.00
Motions research 101122
con cal team meeting 1013/22 24 hous 000
10102 e250
Team meeting; Conf with Judge 10/1722 16vs @ $0.00
and omais 101922 $250
Hearing prep for Mark Medows: 10/25/22- 10hours 000
actual hearing; team meeting 102822 @250

Se
———————
_—
eee seeeet
_— Tol
Tl 7.75000
S750
"Due to bilng restrictions this invoice has been sgnifcanty Tuncated [okaytopay |
‘Submitted, this _26 day of _October, 2022 ATG
Nathan J Wade
EXHIBIT G
 PROFESSIONAL SERVICES AGREEMENT BETWEEN THE FULTON COUNTY
DISTRICT ATTORNEY'S OFFICE AND NATHAN WADE, P.C.

THIS AGREEMENT is made by and between the FULTON COUNTY DISTRICT

ATTORNEY'S OFFICE, (hereinafter CDA" whose mailing address is 136 Pryor Strect,
Atlanta, GA 30303 and NATHAN WADE, P.C. (hereinafter "Atiorney").

WITNESSETIH:
WHEREAS, ICDA entered into and executed a contract dated November 1,2021. This
contract ended on October 31, 2022.

WHEREAS, the ig/CDA intends to recontract the

professional services of Attorncy for legal
services related to anti-corruption matters.

WHEREAS, the services to be rendered are of a special and temporary nature which has been
determined to be in the best interest of the
public to be performed under contract by professional
personnel;

WHEREAS, Attorney has agreed to accept the position as of November 15, 2022. This contract
shall end on May 15, 2023.

WHEREAS, FCDA and Attorney, in consideration of the mutual covenants hereinafter set forth,
agree as follows:

SECTION 1: SCOPE OF SERVICES

Aitomey agrees to provide legal services in connection with FCDA's
anti-corruption matter.
Attomcy agrecs to provide best efforts to the performance of duties and
responsibilities as
outlined below in accordance with
applicable laws, rules, regulations and policies.
Any expansion of this scope will be set forth in a separate letter of
engagement or addendum to
this contract.

SECTION 2: CONTRACT TERM

The term of this contract shall commence November
15, 2022 thru May 15, 2023. 1 FCDA may
terminate this contract at any time, either for conven
ience or default; in this event, FCDA shall
provide thirty (30) days written notice.

Attorney may terminate this contract and withdraw from represe

ntation upon grounds as
provided for by the Georgia Rules of Professional Conduct and/or
any other applicable provision
of :
ov dt ang
(29) days dotiee Se: ved upon the
District Atlorney.
 SECTION 3: ATTORNEY'S COMPENSATION FOR SERVICES
3.1 Attorney shall be compensated at a rate of $250.00 per hour for services provided.

3.2. Attorney is not permitted to work more than six hundred

(600) hours during the total of this
contract. As such, during the duration ofthis contract,
Attorney shall not carn more than one
hundred and fifty thousand ($150,000). This limitation docs not include
any travel and lodging
expenses (See Sec. 3.8).

3.3. Attorney will ensure that work and

responsibilities comply with the following month
limitations: in November 2022, Attorney shall not exceed
fifty (50) hours; in December 2022,
Attorney shall not exceed one hundred (100) hours; in January 2023, Attorney shall not exceed
one hundred (100) hours, in February 2023,
Attorney shall not exceed one hundred (100) hours;
in March 2023, Attorney shall not exceed one hundred
(100) hours; in April 2023, Attorney shall
not exceed one hundred (100) hours; and, in May
2023, Attorney shall not excced fifty (50)
hours.

3.4. Attorney will reccive legal assignments from District Attorney [f

. assignments received,
require Attorney to work more than the monthly limitations sct forth in Section 3.3,
Attorney
must seck written approval from District
Attorney Fani f. Willis before exceeding limitations.
3.5. Attorney shall submit invoice for November 2022 and
December 2022 on the first Friday of
January 2023. Said invoices should be submitted to FCDA's Purchas
ing Manager and Deputy of
Operations. All remaining invoices should be submitted on the first
Friday of the subsequent
calendar month work has been
completed (c.g. The invoice for work completed in January will
be provided to FCDA on the first of
Friday February 2023).
3.5. Bills not submitted within sixty (60) days of due date will not be paid by FCDA.
3.6 Upon the receipt of a timely payment invoice, FCDA will tender
1
payment within sixty (60)
days.

3.7, Attorncy will pre-pay

a travel or lodging costs associated with the
performance of duties
outlined. All travel and lodging
arrangements must be pre-approved by Deputy of Operatio
Dexter Q. Bond, Jr. Travel and ns,
lodging costs shall be adhere to Fulton County's travel policy.
3.8 Receipts for travel and lodging must be submitted to
FCDA with the succeeding monthly
invoice. (¢.g. Lf pre-approved travel is
completed in January 2023, all travel and lodging receipts
shall be submitted to FCDA on the first of
Friday 2023
February with January invoice).
SECTION 4: ATTORNEY AGREES
4.1 'To accept the employm
ent pursuant to the terms of this agreement;
4.2Attorney contracts herein with the FCDA as an indepen
dent contractor, and is N NOT an
employee of the District Attorney's Office for the purpose of
s performing the services
hereunder:
 43 Attorney shall not be entitled to employee benefits provide under this contract such as
d
health or life insurance, retirement benefits, vacation leave or sick
leave, and there shall be no
withholding of taxes by the District Attorncy's Office;

4.4 Attorney cannot represent any party to the of the cases

controversy that is the subject in
which they offer professional services.

SECTION 5: SCOPE OF AGREEMENT

This Agreement supersedes any and all other
agreements, cither oral or in writing, between the
parties hereto with respect to the retention of Attorney by FCDA and contains all the covenants
and agreements between the parties with
respect to such retention in any matter whatsoever.
lach party to this Agreement acknowledges that no
representation, inducements, promises or
agrcement, orally or otherwise, have becn made by any party, or anyone
acting on behalf of any
party, which are not embodied herein, and that no other agreement, statement, or
promise not
contained in this Agreement shall be valid or
binding.

Any modification of the Agreement wil] be effective only if it is in writing and

signed by the
party to be charged. For the purpose of this paragraph and of the entire,
agreement, the signature
of the District Attorney is the only signatu that will bind FCDA.
re
SECTION 6: ASSIGNMENT OF AGREEMENT
This contract is not transferable. Attorncy
may not assign this agreement or any work within
said scope to any other attorney, consult
ant, employee or person,
SECTION 7: GENERAL COMPLIANCE WITH LAWS
Attorney shall be required to comply with all laws and ordinances
applicable to the work.
SECTION 8: OWNERSHIP OF DOCUMENTS
All briefs, memoranda and other incidental Attorney work or materials furnishe
d herein under
shall be and remain the property of the FCDA,
including all publication rights and copyright
interests, and may be used by the FCDA without
any additional cost to the FCDA.
T

Attorney shall be required to execute a separate Confidentiality

Agreement prior to Agreement
being valid said Confidentiality Agreement will be possess
ed by the I CDA s egal Counsel
1

SECTION 9: CHANGES
The FCDA may at any time, in writing, may make any changes in the services to be
performed
hereunder. If such changes cause an increase or decrease in the costs of
doing the work as
defined by the aforementioned scope of services of this
Agreement or in the time required for
this performance to comple an
te, equitable adjustment shall through a written Agreem ent,
 SECTION 10: TERMINATION
This contract is terminable by the FCDA at any time
by written notice to Attorney, either for
convenience or default. By written notice, Attor
ney may terminate this Agreement and withdraw
from representation with the written consent of the FCDA and/o on
r grounds as provided for by
the Georgia Rules of Professional Conduct and/or
any other applicable provision of law.
Upon termination, all briels, reports, summaries, completed work and work in
progress, and such
other information and materials as
may have becn accumulated by the Attorney in performing
this Agreement shall, in the manner and the extent determined
by the FCDA, become the
property of and be delivered to the FCDA. If the contract is terminated
, Attorney shall be paid
the reasonable value for services
performed up until the time of termination.

SECTION 11: SEVERABLE PROVISIONS

If any provision of this Agreement shall be deemed
by a court of competent jurisdiction to be
invalid, then such provision shall be deemed stricken for the
Agreement and the Agreement shal]
be enforced according to its valid and
subsisting terms and provisions.
SECTION 12: GOVERNING LAW
The
ic
y
ts f
one
partics ofthis Agreement shall be governed by the law of the State of
Georgia.

dis ved
their respective names:

Distriét Attorn ani T. Willis Da

5) NatharMWwade Ddte
EXHIBIT H
 LAW OFFICES OF NATHAN J WADE
VENDOR ID# VS0000076036
ATTENTION: Fulton County District Attorney's Office
136PryorStreet INVOICE #14
Atanta, GA 30303
Project Tile: Ant-Coruption Special Prosecutor [
Description Re I
COMPLET BILLED
2) ]
Team interview meeting, Prep 11/7/22 8Ivs@S250 $2,000.00
Meetings with winesses and B22 sms@z0 $1250.00
interviews with OA
PG;Discoverydoo 122 16hs@20 8400000
1022
$PGU infosessionandprep 11422 8he250 2.00000
SPGJ 1115/22 8hrs
@$250 $2,000.00
Jan 6 meeting an Aty cont. 11622 Bhs@250 5200000
Interviow with DCWnite House 11/18/22 Bhs @S250 $2,000.00
Witiness ntoriow and doc review 11/21/22 BIvs@S250 $2000.00
spay 2222 Bhs@S50 $2,000.00
Meeting
MOA with OAre ET testimony prep 11/28/22 8s @S250 2m $2,000.00
mm Swen
Spal
—— 1/2922 BE 8hsG250 5200000
TVR S200000
spay VR1/8022 Sli8hs@250 5200000
S200000
— 0Tota ___| SEIRH 525,250.00
"Due 0blingingrestrictio
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voice hasbeen pifcantysignicantytrun truncated THEE
Please Note, this invoice covers November of 2022 ATG
Submitted, this 19 day of January, 2023
Nathan J Wade
 LAW OFFICES OF NATHAN J WADE
VEND 04VS00000756
OR
ATTENTION: Futon County DistictAtorey’sOff
138PryorGA30303
Aton Sen INVOICE #15
Pret Til: Ant Compton Spec Prossatcr
Description ETE EE
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Mestogs ihOn nogotaiors 12222 ss@zs0 | $125000
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 LAW OFFICES OF NATHAN J WADE
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 LAW OFFICES OF NATHAN J WADE
VENDOR IDK VS0000076036
ATTENTION: Futon County Distict Attorneys Ofice
136PryorStreet INVOICE #17
Alana, GA30003
Prcject Tite: Ant-Corpo Special Prosecutor
Description TEE I
Er
©
Mesting wi SPO: Moetngwth 21123 8Nvs@S20 $2.00000
diigo: Drating
Team strategy meeting anc 2225 BMse20 82.0000
research
[— 2s smsezs0 520000
Mootings with Defense
Motos research and 2625
2102
40w@20 $10.0000
Conference wih Judge: Dratng 21028 Shs GS50 $2000.00
Zoom interviews: Motions 21423 16MeG20 $4,00000
2162
Orang an researc meetings 221/23. 2s $8000.00
with Defense, ovcontary interviews |2/24/23 08250
Team strategy meeting and
research 2/21/23 8 hrs @$250 $2,000.00

PhonoConference and statege ~~ 228/20 Shs GS250 $2000.00

plan

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Please Note, tis invoice covers February of 2023 I_
Submited, this 28th day of February. 2023
NathanJWade
 LAW OFFICES OF NATHAN J WADE
VEND ID 50000076056
OR
ATTENTION: FonGounty Dstt Atom’ Offca
196 Py Set INVOICE #18
Atara, GA50003
Profct Ti: Ant Gomupton Spec Prosecutor
pros DATE HOURS | Cost _—_—
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ES
Mest winTeam.Reng
seach |3123 Bha@S2%0 $2000
Mest winORIngs Moions 3223 ha @250 5200000
vestigation an ve wns smezo s2000m
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 LAW OFFICES OF NATHAN J WADE
VENDOR ID# VS0000076036
ATTENTION: Fulton County District Attomey’s Office
136Pryor Stroot INVOICE #19
Alara, GA 30303
Project Title: Ant Corruption Special Prosecutor
Description DATE [HOURS | Cost |__|
COMPLET| BILLED
ED
Meet
wihTeam,
ingResearch ~~ 4/3/23 8Ns@S250 $2,000.00
Meetingswith OA 4423 BSG250 $2,000.00
Temes
Drafting
asm. amen
a7728
swom OKcE
10 PAY
Travelto interview witnesses: 41023. 40N@250 $10,000.00 -
conduct interviews; document 4/14/23
roquests
Cont. WithOA; travel 4723 Bhs@S250 $2,000.00
Reviewandfle motion 41823 Bhs@250 $2000.00
Inter views
withwitness es;confwith 4/19/23. 24 hrs $6,000.00
oA 42128 @s250
Teamm eetig
andargum entprep 42428 BS@S250 $2000.00
Zoom confwih investigatorsin 4/25/23 8Mis@S250 $2,000.00
other urisdicions
Meeting withteam;powerpoint 4/26/23. 161vs @ 4.00000
roview
_— 42123 250
vem x
-_—
_-_—
_— Total
Tl $35,000.00
S600
"Due to bing restrictions tis invoicehasbeen signicanty truncated
Please Not, tis invoice covers April of 2023
Submitted, this _1st day of May, 2023
Nathan JWade
EXHIBIT I
 PROFESSIONAL SERVICES AGREEMEN
T BETWEEN THE FULTON COUNTY
DISTRICT ATTORNEY'S OFFICE AND NA
THAN WADE, P.C.

THIS AGREEMENT is made

by and between the FULTON COUNTY DISTRICT
ATTORNEY'S OFFICE, (herein
after "FCDA" whose mailing address is 136
Atlanta, GA 30303 and NATHAN Pryor Street,
WADE, P.C. (herein after "Attorney").
WITNESSETH:
WHEREAS, FCDA entered into and executed a con
tract dated November 15, 2022.
contract ended on Ma 15, 2023. This
y
WHEREAS, the FCDA intends to recontract the
services related to ant professional services of Attorney for
i-corruption matters. legal

WHEREAS, the services to be rendered are of a

determined to be in the best inte special and temporary nature which has been
rest of the pub to be
lic performed under contract by pro
personnel: fessional

WHEREAS, Atiorney has agreed to

accept the position as of June 12, 2023. This contract
end on December31,2023. shall

WHEREAS, CDA and Atiorney, in consideration of he mutual covenants herein

agree as follows: after set forth,

SECTION L: SCOPE OF SERVICES

Attorney agrees to provide leg services
al in connection with FCDA's
anti-corruption matter.
Attorney agrees to provide best efforts to
the performanc of dutics and
outlined below in accordance e responsibilities as
with applicable law
s, rules, regulations and pol
icies.
Any expansion of this scope will be set fort
h in a separate letter of
this contract. engagement or addendum to

SECTION 2: CONTRACT TERM

The term of this contract shall
commence June 12, 2023 thru
terminate this contract at December 31, 2023. FCDA may
any time, either for convenience or
provide thirty default; in this event, FCDA shall
(30) days written notice.
Attorney may terminate this contract and
withdraw {rom rep
provided for by the Georgia Rules of Pro resentation upon grounds as
fessional Conduct and/or
oflaw; in this event, Altorney must any other applicable provisi
provide thirty (30) days written notice ser on
District Attorney. ved upon the
 SECTION 3: ATTORNEY'S COMPENSATION FOR SE
RVICES
3.1 Attorney shall be compensated at a rate of $250.00 per hour for services
provided.
3.2. Attorney is not
permitted to work more than one hundred and
calendar month. As suc twenty (120) hours per
h, during the duration of this con
two hundred and ten thousand dol tract, Attorney shall not earn more than
lars ($210,000). This limitation doe
and lodging exp s not include any travel
Sec
enses (See . 3.8).
3.3. Attorney will ensure that work
and responsib
limitations: in June 2023, ilities comply with the following month
Attorney shall not excced ninety (90 hou in
shall not exceed onc hundred and ) rs; July 2023, Attorney
twenty (120) hours. 'the bill for both June 202
shall be submitted on the first 3 and July 2023
Friday of August 2023. For August
November and December , Sep tember, October,
2023, Attorney shall not exceed one hundre
for each calendar months. For d and twenty (12 hours
0)
August though October, bills are dude on the firs
subsequent month (e.g. Augus t Friday of the
t's bill is due the first Friday of Sep For
December, both bills are dude on the firs tember). November and
t Friday of January 2024.
3.4, Attorney will submit all invoices to IDA.Invoices@fultoncountyga.g
ov.
3.5. Attorney will receive
legal assignments from District
require Attorney to work more than the
Attorney. If assignments received,
monthly limitations set forth in Section
must seek written
approval from District Attorney Fani T. Willis 3.3, Attorney
before exceeding limitations.
3.6. Bills not submitted within
sixty (60) days of due date will not be
paid by FCDA.
3.7. Upon the rec
eipt ofa timely payment invoice, FCDA wil
l tender payment within
days. sixty (60)
3.8. Attorney will pre-pay a travel or
lodging costs associated with the
outlined. All travel and performance of duties
lodging arrangements must be
Dexter Q. Bond, Jr. Travel pre -ap pro ved by Deputy of Operations,
and lodging costs shall be
adhere to Fulton
County's travel policy.

invoice. (c.g. If
Ty
co ist hosted
POD A
monthly
pre-approved travel is comple in
shall be submitted to FCDA ted Aug ust 202 4, all trav el and
on the first lodging reccipts
Friday of September 2024 with
August's invoice).
SECTION 4: ATTORNEY AGREES
4.1To accept the em
ployment pursuant to the terms of this
agreement;
4.2 Attorney contracts her
ein with the FCDA as an
independent contractor, and is NOT an
employee of the District Attorn
ey's Office for the purposes of
hereunder; performing the services

4.3 Attorney shall not be

entitled to emplo
health or life insura yee benefits provided under this contract
nce, retirement benefits, vacation lea such as
ve or sick leave, and there
withholding of taxes by the District Attorn sha ll be no
ey' s Office;
 4.4 Attorney cannot
represent any party to the controvers that is the
which they offer pro y subject of the cases in
fessional services.

SECTION 5: SCOPE OF AGREEMENT

This Agreement superse
des any and al] other agreements, either oral or in
parties hereto with respect to the retention of writing, between the
Attorney by FCDA and contains all the covenants
and agreement between the
s parties with respect to such retention in
any matter whatsoever.
Each party to this Agr
eement acknowledges that no rep
resentation, inducements, promis or
agreement, orally or otherwise, have been made es
by any party, or anyone acting on behalf of
party, wh ich are not embodied herein, and that any
no other agreem
contained in this Agr ent, statement, or promise not
eement shall be valid or bindin
g.
Any modification of the Agreement will be effectiv
e only if it is in wri
party to be charged. For the pur ting and signed by the
pose of this paragraph and of the ent
of the District Attorney is the ire, agreement, the signature
only signature that will bind FCDA.
SECTION 6: ASSIGNMENT OF AGREEMEN
T
This contract is not transferable.
Attorney may not assign this agr
said scope to any other eement or any work within
attorney. consultant, employee or
person.
SECTION 7: GENERAL COMPLIANCE WITH
LAWS
Attomey shall be required to com
ply with all Jaws and ordinances
applicable to the work.
SECTION 8: QWNERSHIP OF
DO CUMENTS
All briefs, memoranda and other inci
dental Attorney work or materials furnished
shallbe and remain the herein under
property of the FCDA, incl all publication righ and
interests, and may be used udi ng ts
by the FCDA without any additional copyright
cost to the FCDA.
Attorney shall be required to execute a
separate Confidentiality
being valid; said Confidentia Agreement prior to Agreement
lity Agreement will be posses
District Attorney. sed by the Executive Assistant to the

SECTION 9: CHANGES
The FCDA may at any
time, in wriling, may make
hereunder. If such any changes in the services to be
changes cause an increase or decrease performed
defined by the aforemention in the costs of the work as
ed scope of services of this doi ng
this performanc to Agreement or in the time req
e complete, an equitable adjustm uired for
ent shall through a written
Agreement.
 SECTION 10: TERMINATION
This contract is terminable
by the FCDA at any time by written notice to Attorney, either for
con venience or default. By written
notice, Attorney may terminate this
from representation with the written Agreement and withdraw
consent of the FCDA and/or on
the Georgia Rules of Professional Con grounds as provided for by
duct and/or any other
applicable provision of law.
Upon termination, all briefs, reports, summa
ries, completed work and work in
other information and materials as progress, and such
may hav e been accumulated the
this Agreement shall, in the manne by Attorney in performing
r and the extent determined the FCDA, become the
by
property of and be delivered to the FCDA. Ifthe
contract is terminated,
the reasonable value for services Attorney shall be paid
performed up until the time of termination.
SECTION 11: SEVERABLE PROVISIONS
If any provision of this Agreem shall be deemed by a court of
ent
invalid, then such provision shall be deemed competent jurisdiction to be
stricken for the Agr
be enforced acc eement and the Agreement shall
ording to its valid and subsisting terms and
provisions.
SECTION 12: GOVERNING LAW
The validity of the
Agreement and its terms and pro
visions as well as the rights and duties of the
parties of this Agreement shall be gov
erned by the law of the State of
Georgia.
IN WITNESS WHEMBBO The
R, parties have executed this Agr
tl cir res ec names: eement on the dates indicated by

isfrict Attorney Fani T. Willis Date Nathan Wade

Date
f
EXHIBIT J
 Fulton County

Legislation Details (With Text)

File #: 22-0959 Version: 1 Name:

Type: CM Action Item Open &
-
Status: Agenda Ready
Responsible Government
File created: 42/14/2022 In control: Board of Commissioners
On agenda: 12/21/2022 Final action:
Title: Request approval to renew an existing Independent Contractor Agreement between Fulton County
and E. Anthony Daniels, PC, to provide legal counsel/representation to the Grievance Review
Committee in the amount of $35,098.00. This action exercises the first two renewal options. One
renewal option remains. Effective dates: January 1, 2023 through December 31, 2023. (APPROV
ED
UPON ADOPTION OF THE CONSENT AGENDA)
Sponsors:
Indexes:
Code sections:
Attachments: 1. Independent Contractor
Agreement E. Anthony Daniel.pdf, 2. Contract Renewal Agreement
-
-
GRC
Attorney.pdf, 3. Professional Services Form E. Anthony Daniels.pdf
Date Ver. Action By Action Result

Department
Human Resources Management

Requested Action (identify appropriate Action or Motion, purpose, cost, timeframe, etc.)
Request approval to renew an existing Independent Contractor Agreeme between Fulton
and E. Anthony Daniels, PC, to provide nt County
legal counsel/representation to the Grievance Review
Committee in the amount of $35,098.00. This action exercises the first
two renewal options. One
renewal option remains. Effective dates: 2023
January 1, through December 31, 2023. (APPROVED
UPON ADOPTION OF THE CONSENT AGEND
A)
Requirement for Board Action (Cite specific Board policy, statute or code requirement)
Fulton County policy which provides that contract renewals must be
presented to and approved by
the Board of Commissioners.

Strategic Priority Area related to this item (if yes, note strategic priority area below)
Qpen and Responsible Government

Commission Districts Affected

All Districts ®
District 1 O
District 2 O
District 3

Fulton County
Page 1 of 2 Printed on 1/8/2024
 File #: 22-0959, Version: 1

District 4 O
District 5
District 6 O

Is this a purchasing item?

No

Summary & Bac kg round (First sentence includes Agency recommendation. Provide an executive summary of the action
that gives an overview of the relevant details for the item.)

Scope of Work: Provide legal counsel/representation to the Grievance Review Committee. At the request of
and without additional cost to the County, when/if the Independent Contractor cannot provide legal
counsel/representation, the Independent Contractor shall be required to provide another attorney to the
County to provide these services.

Community Impact: There is no community impact.

Department Recommendation: The department recommends approval.

Project Implications: There are no project implications.

Community Issues/Concerns: There are no community issues/concerns.

Department Issues/Concerns: There are no department issues/concerns.

Fulton County 2 of 2
Page Printed on 1/8/2024
NY YE! : i : :
EXHIBIT K
 Unit 20240106
(2022 )
Vendor Fotal %
:

Law Offices of Nathan J. Wade 200226.51 38.33%

Bradley Arant Boult Cummings LLP 69725.1 13.35%

Arma Forensics LLC 48286 9.24%
BELTMANN GROUP INCORPORATED 38243 7.32%
Christopher A. Campbell PC. 22950 4.39%
GC & E SYSTEMS GROUP 19900.44 3.81%
BONDURANT MIXSON & ELMORE LLP 19080 3.65%
The Cross Firm LLC 18212.5 3.49%
Terrence Bradley 11550 2.21%
Noble Consulting and Expert Witness Services LLC 7896 1.51%
KNOX & ASSOCIATES LLC 7838.91 1.50%
ROLIN FARRAR BARRETT 6330 1.21%
EMORY CLINIC 6300 1.21%
Thomas Aveni 6000 1.15%
Thomas Langley & Co. Inc. 5000 0.96%
Strawberry Patch Enterprises LLC 4675 0.89%
Suzanna Ryan 4656.28 0.89%
1ST ALL FILE RECOVERY USA 3800 0.73%
Trinidad Toby LLC 3200 0.61%
Spacesaver Storage Systems Inc 3035.23 0.58%
WILLIAM T YORK 2490 0.48%
Diana Homeier 2141 0.41%
Gravette Consulting LLC 1881.25 0.36%
AVI-SPL LLC 1868.3 0.36%
Diana Kay Faugno 1750 0.34%
STACEY DESAMOURS 1 600 0.31%
warren Pickard 1575 0.30%
Psychological Associates of Buckhead 500 0.10%
MT! LIMO & SHUTTLE SERVICES INC. 471.2 0.09%

1
Video Impact 345.75 0.07%
OFFICE CREATIONS INC.
:

300 0.06%
Meredith Brooke Oliver McGuffin 283.24 0.05%
Ayonna Johnson 256 0.05%

2
 Unit_20240106-3 (2094 bale)
Vendor Total %
Law Offices of Nathan J. Wade 349750 32.06%
Foley & Lardner LLP 194099.18 17.79%
Thomas Ferguson and Beskind L.L.P 150878.06 :
13.83%
Arma Forensics LLC 59210
:

5.43%
BONDURANT MIXSON & ELMORE LLP 53827 4.93%
Next Generation Recruitment and Staffing Agency 52975.26 :: 4.86%
Cross Kincaid LLC 42787.5 3.92%
The Law Firm of Boddie & Associates LLC 33900 3.11%
Christopher A. Campbell PC. 30600 :
2.80%
Michael Francis LaForte 19603.29 1.80%
Psychological Associates of Buckhead 16290 1.49%
Gregg Marshall Stutchman 9525 : 0.87%
Acme Security Inc 8660.75 0.79%
Nicholas Bioomfield 6412.5 0.59%
Adams Research & Analysis 6137.5 0.56%
Thomas H Burtness 6100 :
0.56%
MICHAEL M HENINGER 6000 :

0.55%
warren Pickard 5875 0.54%
David M. Brani 4812.5 0.44%
GROW heal live lead LLC 4200 :
0.38%
GC & E SYSTEMS GROUP 3251.92 :

0.30%
Martha B Dodd 3000 :
0.27%
Thomas Aveni 2500 0.23%
GL Corbitt Training and Consulting LLC 2250 0.21%
JAZZY AUTO IMAGING 2094 0.19%
Richard A DuCree 2026.6 :

0.19%
Response Technologies Ltd. 2000
:
:

0.18%
QUANINCIA Hill 1710 0.16%
STACEY DESAMOURS 1600 0.15%

1
Combative & Defensive Training Academy 1500 0.14%

Robert Jerome Geller 1450 0.13%

ENGLERT FORENSIC CONSULTANTS LLC 1448.5 :

0.13%

Lashondra Baxter 1200 0.11%

BELTMANN GROUP INCORPORATED 1040 :
0.10%
Rico Dollar 900
:

:
0.08%
PC-MISCELLANEOUS VENDOR 522.5 0.05%
WILLIAM T YORK 500
:

0.05%
Dan-Neika L. Clay 247.5 :
0.02%
Video impact 24.95 0.00%